ML20214T176
| ML20214T176 | |
| Person / Time | |
|---|---|
| Issue date: | 06/05/1987 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| ACRS-T-1592, NUDOCS 8706100152 | |
| Download: ML20214T176 (415) | |
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ORGINKh Ui'41TED STATES O.
NUCLEAR REGULATORY COMMISSION IN THE MATTER OF: DOCKET NO:
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 326TH GENERAL MEETING O
LOCATION: WASHINGTON, D. C. PAGES: 1 - 274-E DATE: FRIDAY, JUNE 5, 1987
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.PUBLIC NOTICE BY THE .
UNITED STATES NUCLEAR REGULATORY COMMISSIONERS' ADVISORY COMMITTEE ON REACTOR SAFEGUARDS FRIDAY, JUNE 5, 1987 The contents of this stenographic transcript of the '
proceedings of-the United States Nuclear Regulatory Commission's Advisory Committee'on Reactor Safeguards (ACRS), as reported herein, is an uncorrected record of the discussions-recorded at the meeting held on the above date.
No member'of the ACRS Staff and no participant at this meeting accepts any responsibility for errors or
. inaccuracies of statement or data contained in this transcript.
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^"# 2 NUCLEAR REGULATORY COMMISSION 3
ADVISORT COMMITTEE ON REACTOR SAFEGUARDS 326TH GENERAL MEETING 4
5 Nuclear Regulatory Commission 6 Room 1046 1717 H Street, N.W.
7 Washington,1D. C.
8 Friday, June 5, 1987 9
The 326th General Meeting reconvened at 8:30 a.m.,
10 Dr. William Kerr, chairman, presiding.
11 ACRS MEMBERS PRESENT:
12 13 DR. WILLIAM KERR
' DR. FORREST J. REMICK 14 MR. JESSE C. EBERSOLE DR. HAROLD W. LEWIS 15 M . CERL E MI HE SON DR. DADE W. MOELLER 16 DR. DAVID OKRENT MR. GLENN A. REED 17 DR. PAUL G. SHEWMON DR. CHESTER P. SIESS 18 MR. DAVID A. WARD MR. CHARLES J. WYLIE 19 20 21 22 23.
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2 DR. KERR:- Somewhere in this stack of papers is 3 the opening statement for today's meeting, which I have
. 4 lost. So I will dispense with it and get right to the -
5 business of tho day, which begins the session to be 6 monitored by Mr. Ebersole, the Operating Experience.
7 MR. EBERSOLE: I thank you.
8 Last Tuesday, we had a somewhat extensive meeting 9 in Bethesda. Out of a number of incidents that have occured
. 10 in the last 60 days, four of these, three of which are 11 really lumped incidents, Fort Calhoun, Catawba and Oyster 12 Creek, we have organized them here in a manner that the last 13 is the most interesting and carries with it a message.which J()
14 is essentially 20 years old:
15 Reactors keep getting in trouble, especially with 16 the reactor vessel head off.
17 By the way, let me refer you to section 7-in the 18 book. There is quite a bit of material in there, and I
- 19. include, as a reminder, perhaps you have forgotten,. the 20 various modes of operation of reactors.
l' ..
21 And of course, one is refueling. They are 22 generally supposed to be down below 140 degrees F, but they 23 can get up and start boiling rather quickly, especially in 24 this refueling mode, obtained quite shortly after a low
'25 power run. You are running with the RHR pumps and holdigg
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' Vbw - 1 - the' temperature down, so that'you can work with.the core, 2 . but you are-not far away. So,'in effect, for a' number of 3- years, this has been largely ignoredas a danger, but now
.4 perhaps we realize it is a substantial contribution not 5- included in'our PRA studies..
6 .DR. SIESS: I thought'this was the way you wanted.
7 'to cool.them down.
8 MR. EBERSOLE : No. This is the RHR pumps.
9 DR. HARK: Tell me just, Jesse, what can happen if I am-at'140 degrees. -
11 liR. EBERSOLE: You can get to boiling, if you 12 -want to' consider, for instance, the total loss'of'AC powerc
~
13 in that circumstance. Thus, you can get to the fire pumps,
}.
. 14 you can uncover the core is a case in point. That is being.
. 15 - discussed-in here, by the way.
I 16 DR. MARK' If I'really push at it, I can boil the 17 water off.
l 18 MR. EBERSOLE: You don't have to push. It will 19- be gone in about an hour or less.
l 20 DR. MARK; But I've got an hour.
i 21 MR. EBERSOLE: If you can get something-going, 22 restore the water. It will be gone into in lurid detail
! 23 here.
24 DR. MARKr In an hour, I could carry enough water
(} 25 in buckets.
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_ ( ^ Vbw 1 MR. EBERSOLE: You are dealing with the boiling M'
2 rate is-an order -- you know, there is a lot of energy. But 3- we will get into-detail.
4 DR. KERR: I would urge that we 'let the Staf f get 5 into'that.
6' MR. EBERSOLE : But.you will have to do it, I 7 might mention, in the face of a horrendous plume of steam 8 coming out of the containment building. It is not pleasant 9 environment which may affect the machinery.
10' Anyway, let me go on and put this into the hands 11 .of the Staff as fast as possible.
12 I refer you to the little pile of papers here, t
13 one of which has a pink cover sheet with number one on it; of )
- 14 But the one wo_will go into as principal guide is'this oneL
. 15 here, the Operating Reactor Events Briefing on June 5.
16 I am going to turn it over to Wayne Lanning, who 17 is in charge of this process now. And Wayne, you see the
- 18 time that is scheduled.
19 MR. LANNING: Thank you, Jesse.
20 Let me take a couple minutes this morning, since
.21 this is the first full committee meeting since the NRC 22 reorganization.
23 My name is Wayne Lanning. I am Chief of the 24 Events Assessment Branch in NRR. Behind me is Ernie Rossi,
(} -25' the Division Director of Operational Events Assessment.
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) 1 We have responsibility for evaluating the O
2 implications of the events that are telephoned into the Op 3 Center. We review those on a daily basis and temper those.
4 We are also coordinating this meeting for NRR.
5 We have following essentially the same procedure 6 that has been used in the past in selecting the events. We 7 ahve provided Mr. Ebersole and Mr. Reed a copy of all the 8 events that we have discussed during the weekly NRR events 9 briefing. Then we had a conference phone call and discussed 10 those events and tried to decide on a number of those, which 11 we would have a trial run for. This is the meeting we had 12 last week with Mr. Ebersole to arrive at the list of events
~S 13 that you have before you now.
(O 14 There are, essentially, six events there. It is 15 my objective to increase the number of events for this 16 committee in the future. I think it is important that you 17 have a feel for what is going on out in the industry 18 concerning operatine events. I think one of the best ways 19 to do that is to give you a brief overview of the various 20 operating problems that are occurring in the industry.
21 For example, in the first discussion this 22 morning, it concerns three different events at three 23 different sites. They are indicative of a management 24 control problem. It is this type of thing that should be of
(} 25 interest to the committee, and we will try to consolidate ACE-FEDERAL REPORTERS, INC.
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(lVbw 1 more of these types of events in the future to give you a
'n J 2 broader overview of operating events. Hopefully, it will 3 trigger subjects for subcommittee meetings. We hope to keep 4 this to an executive type overview and hopefully, we will 5 discuss the nuts and bolts and details of these events in 6 the subcommittee meetings.
7 For example, the last one we have on the agenda 8 today involves loss of RHR.
9 With that in mind, I would just like to start 10 with the presentations. Mr. Rich Lobel will talk to the 11 first one concerning management control of plant activities.
12 (Slide.)
(~T 13 MR. LOBEL: Good morning. My name is Richard s_/
14 Lobel. I am in the Events Assessment Branch.
15 (Slide.)
16 I would like to discuss the first group of 17 events. We grouped these events together with the title of 11 Management Control of Plant Activities. I have been in 19 events assessment work since reorganization, and one of the 20 things I have noticed is that a lot of events seem to fall 21 in this category. So we decided to put these together and 22 discuss, not so much the details of each event, but the 23 structure of the management and operation of the plants that 24 contributed to these events.
() 25 The first event was a loss of all AC power at ACE FEDERAL REPORTERS, INC.
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/ 1- Fort Calhoun.- The cause of this event was performing O
2 maintenance on both the offsite and onsite power systems at
-3 the same time. Power was being supplied by'a 161 kilovolt 4 line.- The other of fsite power line was a 345 kV line that 5 was down for maintenance. The reactor was shut down, but it 6 was being cooled by RHR, and it had all its fuel. assembly 7 still in the core.
8 One diesel generator was down for maintenance and 9 the other diesel generator was in manual.
10 Then some maintenance personnel started 11 performing maintenance on the transformer on the 161 12 kilovolt line, just cleaning the transformer. They
() '13 accidentally hit an oil pressure rel y, which caused the 161 14 kilovolt breaker to open, and they lost all of fs'ite power 15 and all onsite power.
16 It took them three minutes to manually start the 17' diesel generator, and it took them five minutes to restore 18 cooling to the core.
19 The second event, the Catawba event --
20 MR. WYLIE: Are you going to discuss that any 21 further?
22 MR. LOBEL: I can go into it a little bit more.
23 MR. WYLIE: What were the tech spec requirements?
24 MR. LOBEL: They had no toch spec requirements on
(} 25 the operability of diesel generators in that mode.
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, /Vbw 1 MR.'WYLIE: There was no tech spec requirement
-Q 2 required?
3 MR. EBERSOLE : In fact, isn't it true that tech 2
4 . specs generally lead to shutdown. When you are already in 5 shutdown, what the hell do you do? That is the trap'I want 6 to mention. And we will get to that in the Diablo Canyon
]
7 case.
8 Interestingly-enough, this is related to the 9 Diablo Canyon case, in, in fact, that you did lose all power-10 when, I presume, the reactor vessel was off, and it was 11 dependent on central heat transport to cool, except you got 12 it back pretty quick. And I don't know how close they were
() 13 to the prior full power run, in terms of hours or days. I 14 guess you were way out in time.
15 MR. LOBEL: They were out a little in time. They j 16 didn't see any increase in coolant temperature for the brief l 17 amount of time that they lost RHR.
18 MR. EBERSOLE: You combined this, though, with i .
19 the Diablo Canyon case, you can begin to get a feeling of 20 what happened, 21 MR. LOBEL: It has another similarity to the 22 Diablo Canyon event that I was going to talk about in a 23 minute, from the management point of view. And that is one 24 of the things that complicated this event and that took so 25 long for the operators to restore power. They recognized
.( }
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. r~}Vbw 1 right away what happened. They recogn'ized that this ,
V 2 pressure relay had tripped and that the b'reaker had opened' 3 and from the control room, they' attempted to.close the
-.4 breaker, and they couldn't close the breaker. .The reason 5 for that was that the control room people. had no idea that 6 maintenance.was being'done on this transformer, but let me 7 get to that part'in a little while. That has some
- . 8 similarity to the Diablo Canyon event, in that things were 9 going on outside the control room that the control room 10 people weren't aware of for a while.
i 11 DR. KERR: But tech specs would not have 12 prevented this from occurring, would they?
13 MR. LOBEL: No. There was no textbook violation.
( }.
14 MR. WYLIE: There is a lack of tech specs i
, 15 . requirements.
i
! 16 DR. KERR: But even had there been tech specs, 17 even if they had had AC power, would that have prevented i
18 this.
19 MR. WYLIE: With tech specs, you don't take i' 20 certain things out.
21 MR. LOBEL: If they had had a. tech spec 22 requi rment.
- 23. MR. WYLIE: I assume your tech specs for
! 24 operations put limits on how long you can have out one
(} 25 diesel generator for maintenance before you shut down;
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('],Vbw 1 right?
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2 MR. LOBEL: Right.
3 DR. SIESS: Would that improve preventing and 4 controls?
5 MR. LOBEL: It would have tightened up their 6 procedures. It would have prevented them'from getting into 7 this kind of situation, but I don't know whether you would 8 classify that as management control. That would be more NRC 9 control than management control.
10 MR. EBERSOLE: There was long ago proposed a 11 matrix system of tech specs which would account for the six 12 modes of reactor conditions. There is a considerable
(')
v 13 difference in the tech specs for each mode.
14 Does this plant or do any plants maintain this 15 matrix design of the tech specs to accommodate the fact that 16 you are already down, or you are so far from shutdown?
17 MR. LOBEL: I think the newer tech specs, the 18 standard tech specs are better at it than these specs. I am 19 not sure that even the standard tech specs wouldn't have 20 prevented this from happening, which is part of the point 21 that I am trying to make with this, 22 Maybe I ought to reverse the order that I was 23 going to do this and go to another slide first.
24 Prudency and good judgment in control procedures
(} 25 have to be part of the operation of the operation of a power ACE FEDERAL REPORTERS, INC.
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'1930 01~01 11 rlVbw 'l plant. It is impossible for the NRC to monitor everything
-V t 2 and to have a requirement for every contingency that could 3- possibly occur.
4 And I think that is what these events illustrate.
5 One of the events that I will get to, tech specs 6 were violated, but the procedure that violated the tech 7 specs was diset/ased and approved, and in the control room, i
8- and the people went ahead and performed the' actions anyway, 9 oven though there were tech specs.
10 (Slide.)
11 This isn't in your package, but I put this here 12- just more for notes for me to speak from, but the three 13 things I identified going through these events were,
{~)
4 14 procedures are sometimes made up by the utility, that aren't 15 normal operating procedures, some kind of temporary 16 procedures or temporary variations, they are called in one i- 17 case. And a lot of times -- well, I won't say that --
18 sometimes they are not carefully thought out. They don't i
19 get the same kind of review, obviously, or hopefully, that 20 the procedures get that are in the regular procedure books 21 that the operators that are trained with.
22 Maintenance and testing isn't always coordinated 23 between the control room and the maintenance people or 24 between groups of maintenance people,'and it isn't always
(} 25 prudently done.
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. 1930 01 01 12 t" 1. Finally, the point I talked about before, the V>Vbw 2 control room 'isn't always aware of the work that is being 3 .done elsewhere in the plant.
4 MR. REED: I think your judgment and evaluations 5 here are appropriate. It is~ amazing to me'that in the 6 planning meeting, which must have proceeded these two power 7 supply maintenance activities, that the coupling wasn't 8 there and the judgment wasn't there to say, hey, we are.not
~
9 going to take out both sources of AC power or have them 10 jeopardized or weakened.
11 At the same time, it is absolutely stupid. It is 12 a management issue.
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.V 13 MR. LOBEL: They won't intending to. That is 14 part of the point.
15 MR. REED: Well, if you are working on the 16 things, you can always drop a wrench. So it is just poor 17 judgment to do that. It is like taking out the electric 18 ' motor on one RHR pump and the pump on the other train at the i
19 same time or fooling around with them. It is not good 20 planning.
21 MR. LOBEL: Let me add one other point. I don't 22 want to make this worse than it was in-a way. There
, 23 is another source of power at Fort Calhoun. They have a
! 24 13.8 kV line that they used during construction, that they
,(} 25 have kept at the plant, that could have been used, that was ACE FEDERAL REPORTERS, INC.
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/~' I available, that powered some loads. It would power one
\ ,iVbw 2 charging pump, one set of pressurizer heaters, some heat 3 tracing, boron tracing, and one other thing I can't think of 4 right now. But in an emergency, if things had really gotten 5 bad and they couldn't have restored power any other way, 6 they could have used that system. And they did have 7 procedures already written for the use of that system.
8 MR. EBERSOLE: When did they remove the heat from 9 the core?
10 MR. LOBEL: It would have provided makeup to the 11 core.
12 MR. EBERSOLE : But the boiling is a nondesign
() 13 mode, isn't it? That is an unanalyzed condition.
14 MR. LOBEL: It would have been outside the modo 15 of operation for the condition they were in.
16 MR. EBERSOLE: There would have been a 17 substantial steam plume.
18 MR. LOBEL: Let me move on. I don't want to take 19 everybody else's time.
20 (Slide.)
21 The second event was at Catawba 2. Catawba had 22 to perform a load rejection test, where they tripped the 23 turbine and tripped the generator and verified a response 24 for the reactor. They were intending to do this test. They
(} 25 were waiting for an appropriate time, and they got an ACE. FEDERAL REPORTERS, INC.
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r"')Vbw . 1 unidentified leak. The leak was below their tech spec 3
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2 value, but it.was increasing. They were plotting the leak. ,
3 They were aware - they had the leak. They were tracking th'e 4 leak, and they estimated when the leak would get up to tech
.5 spec value, and they still intended to perform this test.
6 So when they got to the tech spec value, which-7 required them to shut down the reactor, they decided -- and 8 this was discussed and planned at a-very high level of 9 management at Catawba, they went ahead and performed the 10 test.
11 So you had an unidentified leak greater than the
.12 tech spec value, that put you in an action statement to shut.
(J 13 down, and they performed a-test that increased the reactor 14 pressure by about 40 psi.
, 15 Now this didn't violate any tech specs. They did 16 a careful evaluation beforehand. The NRC regional people l 17 who looked at this afterwards concluded that they had done a 18 careful review of the situation before they did this test, 19 but there's a question of prudency here.
20 Was it really the right thing to do? It is 21 really just a matter of opinion, I guess. Since the utility 22 had one opinion and we essentially had another, there 23 weren't any violations of tech specs.
24 DR. KERR: So what did you conclude?
25 MR. LOBEL: I would have done the test, if it had
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[;1930'-02102-been my decision.
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'l 2 MR. REED: I think it was a very marginal call.
~3- I think you couldn't cite anyone for going one way or the 4 .other.
5 MR. MICHELSON: What was the method of shutting 6 down at that point? You were at full power.
7 MR. LOBEL: They were at 100 percent power. They 8 tripped the generator which tripped the turbine.
9 MR. MICHELSON: Then they worked back through the 110 reactor from the generator.
11 MR. LOBEL: It turned out.to be PORV packing.
' 12 They had a pretty good idea that that is what it was, 13 beforehand, because they had similar problems before, and
(
14 that went into their judgment. It was1 unidentified by 15 definition, but they had some idea of what the cause was.
16 MR. MICHELSON: Don't they get a reactor trip on 17 generator trip, or do they get it on the turbine trip?
18 MR. LOBEL: I believe they get it through the 19 turbine.
20 MR. EBERSOLE: Glenn, I would like to have you 21 make some observations. This test is potentially hazardous.
22 It is just another challenge. I thought you had a gener'ic 23 understanding that you would do this only rarely and most of 24 the time do it at partial load.
25 MR. REED: You are talking at overspeed.
.(}
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1930 02 02 16 t 1 MR. EBERSOLE: This is turbine overspeed.
b;Vbw 2 MR. REED: Turbine on overspeed under a condition 3 that is different from what this is. Normal load rejection 4 test. I assume this is a test where they open the breaker?
5 MR. EBERSOLE: You unload the generator here 6 instantaneously, and they invite all the functions of 7 overspeed to take place. It is another challenge.
8 MR. REED: I have some problems with overspeed on 9 some units, but this is a fairly late model unit, and I 10 would expect -- what is the overspeed? 100? I wouldn't 11 expect that you would ever get an overspeed on this one more 12 than 7 or 8 percent.
{} 13 MR. LOBEL: All the systems behaved normally.
14 MR. REED: Rather than get into an argument about 15 overspeed testing and turbine roll off, I would rather focus 16 on miscall. What they realized was, I am sure, that there 17 is going to be a somewhat small primary pressure increase.
18 That is_all there is going to be.
19 MR. ROSSI: This is Ernie Rossi. It is my 20 understanding that this was actually a road rejection test, 21 where they were checking the capability of the speed pump 22 system to see if they could ride through a load rejection 23 without tripping the reactor.
24 So there is also the fact that you are doing a
{} 25 test to see if the systems would work, and so there is a ACE FEDERAL REPORTERS, INC.
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1930 02 02 17 t' ^ Vbw 1 question of prudency and doing a test to determine whether 2 the systems would or would not work.
3 So I think it is more than just looking at what 4 you would expect, if everything worked correctly on the 5 test.
6 Another consideration would be, would it be 7 prudent to do a test like this, where you may find some 8 problem with* equipment or design during the test that would 9 make things go in an unexpected way. I don't think we are 10 here to tell you that they did the wrong thing. What we are 11 basically telling you, as Rich indicated, is, there is a 12 question we are giving to you in that context. They 13 violated the toch spec, but our conclusion was that they 14 violated nothing else.
15 So it is a question if that was the proper thing 16 to do.
17 MR. EBERSOLE: Ernie, may I ask you, were they 18 attempting to carry house load on that test?
19 " VOICE: Unit 1 had tripped on similar tests here.
20 They expect that Unit 2 will also trip on this test here, 21 although the design is not supposed to trip the reactor.
22 MR. EBERSOLE: Therefore, what does it do?
23 Transfer to another source of power from the Unit's power?
24 VOICE: It is supposed to dump the steam through 25 the dump valves.
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1930 02 02 18 r";Vbw 1 MR. EBERSOLE: And stay on the turbine generator?
NJ 2 MR. WYLIE: These have generator circuit 3 breakers.
4 MR. EBERSOLE : Then I must ask you, instantly, in 5 recognition of a universal fear of turbine overspoed, is 6 there a frequency trip that would prevent carrying on all of 7 the connected loads in parallel with the generators, should 8 the overspoed trip system fail to function, in which case, 9 you would wreck the entire assembled on parallel AC system.
10 Is there an overspood relaying system over high 11 frequency?
12 MR. WYLIE: On this test, the generator breaker
(} 13 system operatos with all -- it is all tied to the 14 transmission system.
15 MR. EBE RSOLE: So you are not carrying critical 16 loads on the generator. Greatt Forget it.
17 MR. REED: On this issue, I am just wondering, 18 are you sort of logging this one, because you have concerns 19 about management problems? I notice there have been somo 20 instances -- is this part of your logging?
21 MR. LANNING: All those events are factored back 22 in to the SALP program. So it is part of a big process.
23 MR. EBERSOLE: One refinomont, Charlio. Are the 24 main coolant pumps riding on the turbino?
() 25 MR. WYLIE: No, the generator breakers are put in ace. FEDERAL REPORTERS, INC.
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1930 02 02 19 Vbw 1 the aux transformers. j l 2 MR. EBERSOLE: What systems, hypothetically, j
3 :then, would run away and explode along with the turbines?
-4 MR. WYLIE: None.
5 MR. EBERSOLE: It is just the offsite loads
+
6 carried by the generator.
7 MR. WYLIE: The only time that you carry your own 8 auxiliaries on a trip is when there is something that will 9 'soparate you from the system and the breakers in the l
10 switchyard.
!' 11 DR. KERR Is this a test that is required for i
1 12 some reason?
(} 13 MR. WYLIE: It is not a required test.
14 MR. LOBEL: I believe it is part of a start-up
]
l 15 test.
I 16 MR. WYLIE: It is an electrical test of the L
i 17 utility to demonstrate the load rejection capability.
i 18 MR. ROSSI: Charlie, it is our understanding -- I 19 was just talking to the Region I person here -- that this j 20 plant was designed to take a full load rejection and t
21 maintain things liko reactor coolant pumps on the generator.
22 I don't know whether they were doing that at the
{ .23 time of the test, but I thought they woro designed for that.
j 24 MR. WYLIE: They are designed to do that.
)
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<~ 1 MR. ROSSI: Then you would loave the house load k_)1Vbw 2 connected to the generator.
3 MR. WYLIE: Generally, they don't run that test 4 this way.
5 MR. ROSSI: But I think the design would --
6 MR. WYLIE: That is what I said a minuto ago. It 7 is designed so that if you have a fault that would shut the 8 plant, let's say -- well, loss of offsito power. Then you 9 open the breakers up and run back to the houso load. It is 10 designed to do that, but this particular test opens the 11 generator breakers and checks the system for load rejection 12 capability run by the reactor.
(} 13 VOICE: That is correct. The only difference is 14 that the reactor coolant pumps are, indeed, run off the 15 generator. When you open the gonorator up to the breaker, 16 you got the fast transfer.
17 MR. WYLIE: There is no fast transfer. You don't 18 transfer anything from this plant. Soo, the generator 19 breakers on the generator terminals betwoon the stop up 20 transformer and the gonorator breaker are the auxiliary 21 transf o rme rs . So when you open that breaker, automatically 22 you open up the transmission system. You never soo a 23 transfer.
24 MR. EBE RSOLE: Thoro is a generic matter hero,
(} 25 Ernio. It has boon oponed up for sometime. If you, in ace FEDERAL REPORTERS, INC.
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2 trip, you must look particularly on speeding every machine '
f 3 connected with it, along with its overspeed. Therefore, the i 4 turbine overspeed must be extrapolated, not only to blowing 5 the disk but everything else in the house, which could be a 6 disaster.
- 7 MR. ROSSI
- I think that is generally looked at.
8 MR. EBERSOLE: I doubt it very much. I think we 9 need to make a generic check of that.
j 10 DR. KERR I am not going to spend all of our
- 11 time on the first two events, but if we are going to get.to L 12 the others.....
] (} 13 MR. REED: In trying to promote issues out of i
I 14 these incidents, I would like to point out something here in j 15 our floundering around.
, 16 I soo this as a marginal management call, but I i
17 do see an impact, cosmica11y, with respect to station I l 18 blackout. Ilearing an utility has designed and attempted to 19 go to house load with their design system. So that the i-l 20 decision that we have made that this kind of system of i
1 j
21 trying to pick up house load on trip is not allowable as a j 22 blackout preventive device, that is the decision. l l 23 Do you soo what I am talking about?
i
. 24 DR. KERR It is not allowable by whom?
When we talk total loss of AC.
(} 25 MR. REED:
I I r i
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("Nbw 1 DR.1KERR: You said it is not allowable. What
'% ) .
2 did you mean?
l 3 MR. REED: It is not allowable in the formulation
, 4 of the. blackout rule.
1 i 5 MR. WARD: It is not credited.
6 MR. REED: Transfer to house load is not credited -t 7 under the station blackout rule. '
n 8 MR. ROSSI: I think that is correct.
9 MR. MICHELSON: It didn't work in this case i 10 either, as I understand, or maybe I misunderstood.
I 11 MR. ROSSI: My understanding is, it tripped on
- f. 12 this event, and of course, not all Westinghouse plants are
{}
~
13 designed to be able to sustain a-full' load rejection anyway.
14 I don't know what the percentage is, but some have large 15 capabilities and the intended design was to be able to 16 sustain a full load rejection from full power without ,
i 17 tripping. A large number of other plants are not designed
- 18 for that. They are designed for load rejections more like 1
- 19 50 percent. I think Point Beach may be one that is about 50 j 20 percent. ;
21 MR. REED: 55 percent.
i 22 MR. MICHELSON: Clarification. Was the test 23 successful or unsuccessful in the case of the first unit. I i 24 thought you said it was unsuccessful, t t
5
(} 25 MR. ROSSI: I believe they tripped on both units, ACE-FEDERAL REPORTERS, INC.
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>Vbw 1 The tripped on both units, although none 2 of the criteria is dependent.on that trip.
3 MR. MICHELSON: By " trip," do you.mean.that the 4 reactor tripped, so-you weren't able to fall back on house 5 loads in either case, so it didn't work?
6 VOICE: The acceptance criterion was that the 7 turbino did not overspeed.
8 MR. MICHELSON: Then that was the.only thing you 9 were looking for. That is different. I thought we'were 10 looking for ability to run back-to house load.
11 -MR. ROSSI: Well, the ability to sustain a full 12 load - rejection without tripping, would not be one of our -
13 safety requirements.
q{ ) ~
i 14 MR. MICHELSON: That is why we don't give them-i 15 credit. -
i l 16 MR. ROSSI: When they do or don't pass that' test i-17 is between the utility and the vendor AE that is on the-
, 18 systems.
i i; 19 MR. LOBEL: Let me go on.
l 20 The last event was at Oyster' Creek.
j 21 (Slide.)
l 22 On April 23 and 24, the reactor was having a l
l 23 problem with a relief valve and decided to shut down to pick l 24 the valve.
i
{} 25 You don't have to go through this whole drawing.
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< - 1930_02:02 24
(""}Vbw 1 Let me just point out that here is the drywell and the torus V.
2 .and.some other' valving I will get to. They wanted to shut 33 down. Their containment was inerted. So one of the things 4 'they needed to do is, in order to shut down and get people 5 into the containment was to deinert the containment. They 6 decided to do this and proceeded to do it. While they were 7 doing it, they followed the practice that had been in 8 existence'since 1977 -- it was written into their formal 9 procedures of blocking open a vacuum breaker from the 10 reactor building to the torus to speed the deinerting. The 11 deinerting wasn't going fast enough.
12 This was around 11:00 o' clock at night they
{} 13 started. So around 3:00 o' clock in.the morning, the crew 14 shift > supervisor and the shift technical adviser got 15 together and decided that they would write what Oyster Creek 16 calls a temporary variation to allow them to open another 17 vacuum breaker, two other vacuum breakers from the drywell 18 to the. torus. They were at 5 percent power when they did 19 this.
20 Their tech specs required containment isolation.
21 Essentially, what they had done is, they opened a path, 22 where if they had had a LOCA, steam would have been able to 23 flow into the torus without being condensed.
24 It would have been channeled into the water in i
1 25 the torus. It would have been channeled above the water in
("}
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'jVbw 1 the-torus and.overpressurizing the containment. They didn't j .
2 realiie this, and it wasn't until 7:00 o' clock in the n
3 morning at a change in shift, that the ongoing shift 4 recognized the problem.
5 MR. EBERSOLE: Don't the boiler people recognize 6 pressure bypass'as potentially blowing up the containment in 7 a matter of ten minutes, if they don't suppress?
8 MR. LOBEL: I am not sure what the time is.
9 MR. MICHELSON: There is a tech spec on the 10 operability of that valve. I thought you could only have 11 one out at a time, or you had to shut down immediately, if 12
~
you. lose more than one of those vacuum breakers, and then
') 13' ony for a few hours, even with one open.
{
14- Don't they use those tech specs while they are 15- still at 5 percent power?
16 MR. LOBEL: Yes.
17 MR. MICHELSON: They just ignored that i
18 requirement? Okay.
19 MR. LOBEL: This is the case I was talking about 20 before, where there was a requirement in the tech specs, and 21 they went ahead and wrote a temporary variation.
22 MR. EBERSOLE: But do the operators understand 23 the physical reason for the tech spec requirement? For 24 instance, are they required to know about the Brookhaven
(~) 25 Study-that says you've got maybe ten minutes before you are U
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Q["iVbw 2 MR. LOBEL: I can't answer that.
3 MR. EBERSOLE: I have a feeling that they write 4 the tech specs and they are in blind ignorance of why it is 5 written.
6 (Slide.)
7 MR. LOBEL: Region I investigated this event, 8 wrote an inspection report. There was an enforcement 9 conference scheduled with the licensee for June 9 to talk 10 about this. The conclusions of the inspection report are 11 that opening both vacuum breakers was a violation. Each 12 separately was a violation of 5059, and that it was a
(~] 13 violation of tech specs, and it was a unreviewed safety v
14 question.
15 MR. MICHELSON: Clarification on the vacuum 16 breaker valves. When you exercise those, as you have to do 17 every 30 daysf I thought the exercising cycle was automatic. ,
18 In other words, I am saying, is it possible to 19 open and keep these valves open by remote control? I didn;t l
20 think it was even possible to jack them open. If it is, i
i 21 then I would ask a lot of questions about control circuitry, L 22 fires, and so forth, to see whether we start jacking these i 23 valves open as a result.
l 24 I thought it wasn't physically possible.
! . /"T 25 MR. LANNING: That is how they did it.
! (_)
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2 them open. I didn't think you could jack them open.
3 MR. LANNING: This is an old plant.
4 MR. EBERSOLE: You mean they have a mechanism by 5 which they can remotely open these?
6 1.R. MICHELSON: And keep them open 7 MR. LANNING: I don't know if it was remotely 8 operated from the control room.
9 MR. EBERSOLE: How could they go inside, if it 10 was inerted?
11 MR. LOBEL: They didn't do it from inside. They 12 might have had some way of doing it from some other 13 location.
{' }
14 MR. MICHELSON: If you have got a way of opening 15 these things outside, you had better look for accident 16 effects, system interactions. I thought it'was strictly 17 automatic.
18 MR. EBERSOLE: There are other exercises in a 19 typical GE design, which is unique to the GE design.
20 DR. KERR: You said that they did this, or at 21 least opened the second valve, because inerting was not 22 going fast enough.
23 Does that mean that the containment de-inerted 24 more slowly than would normally be the case?
("T 25 MR. LOBEL: Yes. They knew the normal rate of
%)
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~ Nbw I de-enerting, and it was there opinion that this was going 2 slower. So they decided to speed up the process by opening 3 this other set of vacuum breakers.
4 DR. KERR: Is there any reason why it was going 5 more slowly?
6 MR. LOBEL: I don't know.
7 MR. EBERSOLE: I think that is an interesting 8 generic issue.
9 MR. LANNING: We will follow up on that.
10 MR. MICHELSON: We just got done in the full 11 committee. I had to write the letter on Generic Issue 61.
12 This blows my mind a little bit.
I 13 DR. KERR: I want to find out about the de-d' 14 inerting. Is there some other way to de-inert, to do what t
15 they did?
16 MR. LANNING: No.
17 MR. LOBEL: I am not sure. I am not sure. There 18 must be, because, what they were doing violated the tech 19 specs.
20 MR. MICHELSON: It is my opinion that they opened 21 the drywell inerting valves to de-inert. I didn't realize 22 they went backwards to the torus.
23 MR. LOBEL: This was just an aid to de-inerting.
24 It wasn't the normal de-inerting method.
(~} 25 MR. EBERSOLE: There is something wrong with
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1930 03 03 29 Vbw 1 their de-inerting system which we haven't mentioned.
2 MR. LOBEL: The significance of these events, 3 obviously, as we have been talking about them, is the plants 4 seem more vulernable to unanticipated events. Each one of 5 these can go through and imagine the types of things that 6 could have happened, if one more system had failed or one 7 more piece of equipment had not worked or the operator had 8 made another error.
9 DR. KERR: Suppose they had called the NRC and 10 asked for permission to open valves, would they have gotten 11 that?
12 MR. LOBEL: Hopefully, not.
~5 13 DR. KERR: I ask, because I see occasions in (d
14 which one can call up the NRC and say, hey, we have two 15 diesel generators out for 30 minutes or something, which one 16 would normally not be able to do. It would have been okay, 17 if they had NRC licensing.
18 MR. LOBEL: Would it have been okay, if they had 19 gotten NRC blessing?
20 MR. ROSSI: I don't know what the outcomo under 21 this one would have been, but there are mechanisms under 22 certain circumstances for the licensee to come to the NRC 23 with an appropriate analysis of the situation to show that 24 there is a safe period of time.
25 DR. KERR: For example, the likelihood of a LOCA
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. 1 'during this time interval is probably very low.
2 MR. ROSSI: That is'true. If they could make the 3 case that there is a very low probability at the time, sure,-
4 in some cases, they may be able to get either a tech spec
- 5. change or something of that sort.
'6 MR. LOBEL: The difference here, in this case --
- 7 MR. ROSSI: Could I suggest that we probably-8- ought to move on to the next event. We have got a large 9 number here, and I-think you have gotten a general flavor.
10 MR. EBERSOLE: One thing, though. -The punch line 11 here, Bill, for all of us'here in the community at large is 12 the bottom line, but what is the follow up? Do we need to
()
=13 add anything to the follow up for Staff to execute here?
14 Can you comment on the follow up and then jump to 15 the next topic?
4 16 MR. LOBEL: Let me make one more point about the 17 last one real fast.
18 If they had asked the NRC for permission to do 19 this, they would have had to write a safety evaluation. The 20 operators who did this action had no idea, did not realize 21 what it was that they were doing. It wasn't until the next 22 shift came in that they were told what it was that they had 23 done. At least, if they had gone through the step of 24 getting NRC approval, everybody would have realized what the
(} 25 situation was.
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,7Vbw 1 DR. KERR: Would that have had any influence on
(_)
2 the risk?
3 MR. LOBEL: On the risk?
4 DR. KERR: The fact that everybody knew what they 5 were doing.
6 MR. LOBEL: No.
7 DR. MOELLER: And why did the incoming shift know 8 more than the graveyard shift?
9 MR. LOBEL: It was just a matter of recognition 10 of the status the plant was in. I don't think that has any 11 significance, except a new person recognized the status.
12 MR. ROSSI: I think one of the concerns with
{} 13 these events, or a major concern with these events, is not 14 so much what happened or could have happened with these 15 events, but it is thinking about the process that is used by 16 the licensees in reviewing what they do and understanding 17 what people are doing in this kind of thing and how that 18 might extrapolate to other, more serious kinds of 19 situations.
20 MR. REED: A couple of quick punch lines. I am 21 sorry to belabor these. Are these rotating shift? In other 22 words, the point that Dave made. Is this third shift?
23 MR. ROSSI: I don't know, specifically, on this 24 plant. I don't know the specifics on this plant.
{} 25 MR. EBERSOLE: I hope we can get to that punch ACE FEDERAL REPORTERS, INC.
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'l- line. What-is the reactive effort and whether we need to
/'
2 have direct quality control? What is this?
3 MR. LOBEL: I think in each of these cases,-the 4- region and NRR, particularly the regions, I think,'in these 5- cases, have taken action to fix the problem, and not just-6 fix the immediate problem to go further. The Oyster Creek 7 problem resulted in a regional review that looked at the 8 whole concept of how temporary variations were handled at 9 Oyster Creek, that they were lax, that they were sometimes 10 inconsistent, and the licensee is committed to fix this 11 whole issue of how he handles procedures. So not just this 4
- - 12 particular event was addressed, but the whole management
(} 13 weakness at Oyster Creek is the subject of regional actions 14 and enforcement.
15 MR. EBE RSOLE: Bill, we are supposed to either 16 have a bottle up or not bottle up.
17 Do you believe we should have distributed to us 18 the reactive response to this set of incidents that is 2
19 issued?
20 DR. KERR: What is your recommendation?
21 MR. EBERSOLE: We hear you say you are going to 22 do something. At that point, it just blows into the wind, 23 and I never know.
24 MR. LOBEL: It is being done. What I am saying
{} 25 is, I am not aware, and I checked into this a little, that ACE-FEDERAL REPORTERS, INC.
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1930 03 03 33
(~)Vbw I there is any major program at the NRC addressed just to G
2 these types of issues. Each one of these issues that shows 3 a weakness is addressed by the regions. The Oyster Creek 4 one, which was, perhaps, the grossest, in terms of 5 violations and not realizing the situation that the plant 6 was in and purposely putting the plant in that kind of 7 situation, has had an aggressive investigation by Region I.
8 They have written an investigation report. There is going 9 to be an enforcement conference on June 9. There have been 10 a couple of violations of regulations that have been cited 11 by the Region that will be addressed.
12 And like I say, it is not just this particular
(} 13 event. They have gone back and looked at the whole 14 management structure and how it fits procedures.
15 MR. EBERSOLE: You see, it sounds great, but I 16 must say, you know, it gets to a negative state.
17 DR. KERR: Why don't we talk about it at the end.
18 MR. ROSSI: Jesse, I don't know that these 19 particular events warrant any particular action or the 20 Region doing anything in this case. They are of interest, 21 and I think there are other plants that have similar 22 problems. And one of the things that we do from time to 23 time is to collect these events or put the more significant 24 ones together and put out information notices at the
{} 25 regions, and obviously, continue to work with licensees. So l
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-7^^,Vbw 1 I don't know that there is anything specific that we need to C/
2 get back to you on on these three.
3 MR. EBERSOLE: Thank you.
4 MR. LANNING: Thank you, Rich.
5 The next presentation will be by Helen Pastis, 6 who is the Project Manager for Oconee. She is going to 7 describe the problems with the heat exchanger at Oconee.
8 MR. EBERSOLE: This is a case of the fouling of 9 the heat exchanger to the point where the transfer 10 characteristics of the heat exchangers are lost in a period 11 of slow mode. If it is always slow, there-is no big deal.
12 YOu can always back them up one at a time and clean them 13 out, but that is, in fact, a patching operation, and what it
.( }
14 leads to is the thought that maybe there is a potential for-15 fouling due to biologic scaling or whatever being~ suddenly 16 released or to earthquake or storm, high precipitation or 17 whatever, washing mud and filth into the heat exchangers and 18 stopping them up so fast that you have,'in essence, a total 19 loss of heat sink.
f 20 So this is the general theme that I think you are l
l 21 going to talk to. Thank you.
22 MS. PASTIS: Good morning. My name is Helen i ..
! 23 Pastis, the Oconee Project Manager.
I 24 I will make my presentation, and then I do plan
{} 25 to address your concern, Mr. Ebersole. I know you brought Ace FEDERAL REPORTERS, INC.
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("'ybw 1 it up during the subcommitte meeting.
O 2 This affects all three units. They had a common 3 problem. What precipitated the whole event, from March 30th 4 to the 31st, Unit 3 was shut down from its restart. It was 5 started up in the refueling outage, and on the way up, Duke 6 Power Company decided to shut the unit down.
7 The problem, of course, is fouling of the heat 8 exchangers in the low pressure injection and reactor 9 building cooling unit systems. .Later on in the week, Units 10 1 and 2 were reduced in power.
11 I would like to emphasize, and then I will got a 12 little bit more into it, it was not a sudden realization
(~} 13 that there was fouling in the heat exchangers, but it was R/
14 the result of a now consultant they had hired that showed 15 that those coolers would not have boon able to perform their 16 designed rating during a LOCA, so there was new analysis, 17 and results of that analysis that precipitated the event.
18 To go briefly into a little systems overview, 19 because, Oconoe, being an older plant, is a little 20 different.
21 (Slide.)
22 Oconeo does not have an intormodiary loop between 23 the raw lake water and the cooling of the heat exchangers.
24 There is no component cooling. It is directly, the lake
, (^)
%J 25 water goes straight to the heat exchangers.
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1930 03 03 36 r?Vbw 1 On this Vugraph, what I would like to show is, V
2 you havo Lake Kiwi, and the condensor cooling water system 3 takes water through the low pressure service water system 4 and sends it on directly to the heat exchangers.
5 on the next Vugraph, you see how the low pressuro 6 service water system takes then the lako water and sends 7 that on to the heat exchangers.
8 (Slide.)
9 MR. EBERSOLE: The low pressure service water 10 system is not draw off the condensers surge water. It is 11 drawn directly out of the laker right?
12 MS. PASTIS: It does both; that's correct. You
{} 13 will have the condensor cooling water pumps and those pull 14 lako water and send it on to the low pressure service water 15 system, but the low pressure service water system has its 16 own pumps.
17 MR. EBERSOLE: Direct access to the lako?
18 MS. PASTIS: In a manner if speaking, it can, 19 yes.
20 MR. EBERSOLE: Does it have an option of taking 21 condonsor circuit water as uptake or the direct lake uptako?
22 MS. PASTIS: The condonsor is a terminology that 23 is used by the plant. Even though it is called condonsor 24 cooling water system, it is raw lake water, no matter what
(} 25 system. It is raw lako water. So it does take raw lako Ace FnouRAL REPORTERS, INC.
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2 MR. MICHELSON: Does it take suction directly 3 from the reservoir or from an intake canal? That is, at 4 some other gravitational level.
5 MS. PASTIS: The condensor cooling water system 6 is the system that is the intake structure. Those are the 7 pumps and the intake structure.
8 MR. WYLIE: To answer your question, there is a 9 canal.
10 MR. MICHELSON: They don't have to run the 11 condensor circulating water pumps to get all the suction 12 indefinitely that they need.
{}
13 MS. PASTIS: That is correct.
14 The condensor cooling water system. is not a 15 safety-related system. So under emergency conditions, that i
!' 16 is dropped, or it is load shut, and the low pressure service 17 water system is your emergency system.
! 18 MR. EBERSOLE: But its suction uptake is the same l 19 as the condensor circuit water systonm?
20 MS. PASTIS: Yes.
21 MR. EBERSOLE: So it is dependent on that pipo 22 and the U bond that we heard about earlier?
23 MS. PASTIS: Yes, it is.
- 24 MR. EBERSOLE
- Go ahead.
(} 25 MS. PASTIS: You remember the previous event very
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2 (Slide.)
-3 As I said, what precipitated the whole event was
,4 the new analysis. Up to now Duke Power Company had been 5 -doing~their own analysis in-house. The difficulty was to 6- take test data that was derived from normal conditions, 7 normal operating conditions, and correlate that to what the ,
8 performance in heat transfer capabilities would be on the 9 heat exchangers under emergency conditions.
10 They decided to go to a. consultant and have 4
11 computer codes run to see what the performance of the 12 heaters would be during emergency conditions, .af ter they did 13 various surveillance-testing.
- - (}
j 14 When the results came in from the consultant,'it 15 showed that for Unit 3, it would not be capable to support 16 any power operation at all, and that is why the unit was l 17 shut down. It would not be able to perform its safety 1
18 . function, if an emergency had occurred at full power or any j 19 power for Unit 3. So they shut the unit down. Units 1 and ,
l 20 2 were then later reduced to about 60 percent, initially, 21 and then up to 80 porcent. Wo discussed the situation with 22 the utility. We then issued a confirmatory order on April J
23 10 that essentially did three things.
24 One is, it did limit Units 1 and 2 in power, so
{} 25 the unit would be within a performance of the heat
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("]Vbw 1 exchangers with the fouling that existed at the time, then 2 required that Unit 2 be cleaned and tested. Unit 1 would be 3 cleaned, but tested in August, when it comes down for a 4 refueling outage. And Unit 3 would be cleaned and tested 5 before it restarted.
6 The other condition was, we asked that the high 7 flux trip be also reduced the corresponding power level.
8 MR. MICHELSON: Excuse me. You talk only about 9 lake sediments. Was that the only material that was fouling 10 the system?
11 MS. PASTIS: As opposed to biological?
12 MR. MICHELSON: Yes.
13 MS. PASTIS: The fouling problem was caused by
/~}
14 lake sediment.
15 MR. EBERSOLE: Now this is the point I think 16 have to bring up. The progressive slow loss of transfer is 17 something you can deal with, provided there is no potential 18 for a step change to a change where you can't reject 19 adequate amounts of decay energy for shutdown.
20 When I see the word " sediment," I begin to look 21 at the invisible structure, or I think about it. How close 22 it is to sudden collapse of mud bottoms, due to having the 23 suction uptake too close to the soft mud? Can that be 24 disturbed by seismic events? By high rates of rainfall with
/~ 25 those bald banks they have down there in dry weather? By
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- %J 2 loss due to excess sedimentation can be a critical matter, <
3 and I think , generically, plants are obligated to see there. ;
4 is no potential for sudden loss of this total transfer 5 function, and I don't hear that as a generic claim. And we 6 will find in this design.
7 There is another one for Oconee, I think, which 8 is somewhat different from this, which may even be worse 9 than this in respect to sudden sedimentation loading. '
10 MS. PASTIS: I would like to make a couple 11 points, before I do put up my Vugraphs and address the 12 question.
{} 13 Oconoo is a much older plant than McGuire. It 14 started off in '72 '73, and if I did my math right, that is 15 14 to 15 years of operation.
f 16 On the other hand, McGuiro has been operating for 17 four or five years.
1 L
- 18 However, the problem was originally identified on
{ 19 McGuire. That is why Oconoo had started doing survoillanco, 20 so that you don't have a direct correlation there.
i 21 The other point that I would like to briefly 22 montion horo, and I will got a little bit mre into it, once 23 I put the Vugraphs on, is that both McGuire and Oconoo get r
- 24 their water from lakes. Oconoo is Lako Kiwi and McGuido is i
1
{} 25 Lako Norman.
ace. FEDERAL RneonTuns INC, Nationwide Cmerage
) l 202 347 3701 mMb33MM6
1930 03 03 41
,7';Vbw 1 Those lakes have naturally what is called lako L) 2 turnover. That is, the thermal patterns on the~1ake cause 3 it to turn the water over and by turning it over, it does 4 disturb the sediment enough. And they have at 5 McGuire major problems with the sediment and the fouling, 6 because of lake turnover.
7 8
9 10 11 12 iv) 14 15 16 17 18 19 20 21 22 23 24 p 25 v
Acti-17it utinAi. Riii>onriins, INC.
202 m nm Nationwide Cmerne Mm-U6 udo
1930 04 04 42 llhVbur 1 One question one could ask is maybe late 2 turnovers could be closely related to what seismic events 3 could be.
4 MR. MICHELSON: This is a far more serious 5 problem on rivers than on lakes, of course. Some nuclear 6 plants have had a large number of turnovers, to the point of 7 having to replace a large number of intakes after a few 8 years of operation.
9 So I think that there is a generic lesson to be 10 learned which would make you look at the rivers, 11 particularly in the southern United States, a lot more 12 carefully, and there you get biological fouling as well as 13 sediment fouling, and the two together get real interesting.
14 MR. LANNING: There is a generic issue talking to 15 dirty service water systems.
16 MR. EBERSOLE: Does it say specifically sudden?
17 MR. LANNING: I don't think it concludes.
18 MR. EBERSOLE: That is whero it falls apart 19 because unless you toko the sedimont -- you can always deal 20 'with a progressive thing.
21 MR. MICilELSON: Asiatic clama like to movo in 22 shake pipes.
23 MR. E13ERSOLE : They move, too, if you just dump a 24 little more chlorine in than you think you should. You havo 7-i )
K_/ 25 a load of them como off in your face.
A n .17111)l!RAl. Ill!!M)R ll!RS, INC.
20244 Woo Nanonmde Gncrage N o W. (Mi
1930 04 04 43 3
L s ,1 bur. 1 DR. KERR: We need to discuss this as a committee 2 later on.
3 MR. EBERSOLE: Right.
4 DR. SHEWMON: One point of clarification. Is 5 this a matter of filling up.the bottom corridor, or does 6 this stuff begin to cake on the tubes and degrade all of 7 them? What is the nature?
8 MS. PASTIS: My impression is that it cakes on --
9 excuse me. Paul Willis here, from Duke Power. Is that 10 correct, Paul?
11 MR. WILLIS: Can you repeat the question?
12 DR. SHEWMON: The question is whether it is 13 uniform on all tubing or whether you just sludge in the 14 bottom fraction of it?
15 MS. PASTIS: My impression is that it cakes on.
16 DR. SilEWMON: Relatively uniformly?
17 MS. PASTIS: Because they had difficulty cleaning 18 it. It is not a matter of just flushing it out. They 19 actually have to put brushes and scrub it and put detergent 20 in.
21 MR. MICilELSON: It is a little more complex than 22 that. In nuclear plants, a lot of those systems are very 23 low in eleva ion, and the sodinent tends to end up in the 24 basement.
25 DR. KERR: Let's give the man here a chance to Acti Fl!!)t!RAI, RiiPoRTliRs, INC.
202 347 3700 Nailonwide Cmcrage m))6 M46
r 1930 04 04 44 (mj7 bur 1 comment, please.
2 Identify yourself and use that mike, please.
3 MR. WILLIS: One is the reactor cooling building 4 heat exchangers and the air-water heat exchangers, and they l 5 are not straight-through tubes or anything. They are bands, 6 and you have to take it apart. Essentially, physically get 7 in there and scrub it out.
8 DR. SIIEWMON: My question was not how you cleaned 9 it, but how it was degraded. Where was the mud, on each 10 tubo?
11 MR. WILLIS: It was associated with the LPSW I 12 unit.
( 13 DR. S!!EWMON: Is it caked on each tubo, or does
! 14 it lio as sludge on the bottom?
l l
15 MR. WILLIS: It was uniform throughout the tubo.
j 16 DR. SilEWMON: Thank you.
17 (Slido.)
l 18 DR. KERR Please continue.
I
! 19 MS. PASTIS: In addressing Mr. Ebersolo's i
l 20 quontion, this is tho intake structure for Oconoo. This in l
l 21 what you would call the condonsor cooling water system.
22 This piping then loads to the low prosauro servico water 23 system, but than takes the water and sends it on to the heat l 24 exchangora for the low pronouro injection and the reactor
( 25 building cooling unit heat exchangers.
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202.m.nm Nation *ide cmcrage mnmn<M6 L ___ _ _ __ _ _- __
1930 04 04 45 lhVbur 1 This is the pump, the condenser cooling water 2 pump.
3 Mr. Ebersolo, you had asked me what the distance 4 is. The distance between here, which is the pump, and this 5 is a concrete pad in the lake. The pump is at 764 feet, 6 6 inches, and the pad is at 761 feet. So you have a clearance 7 of three and a half feet.
8 For Oconee, in looking at their design basis for 9 tho lake, which is their ultimate heat sink, they have put a 10 weir in the intake structure, essentially a wall. But if 11 you do use Lake Kiwi, the wall will retain a certain amount 12 of water as your ultimate heat sink.
13 MR. EBERSOLE: Is that retaining wall next to the 14 uptake structure? That thin retaining wall, is that by any 15 chance a driven retaining wall? Is it seismically 16 competent? Is it a seismically competent wall?
17 I see a retaining wall next to the vertical 18 uptake pipe.
19 Do you see it?
20 The inner one. The one on the inside. There in 21 an earth fill behind it apparently. There is mud all over 22 that.
23 If that wall -- if it in a frangible wall under 24 any kind of physical influence, you are in trouble.
e ,
'uJ 25 MS. PASTIS: That particular '<all I don' t know.
ACl! I7l!!) lira 1. Illil'OR il!RS, INC l 202 mmoo Nanonwue nnnage mu3mfM6
1930 04 04 46 (w,)bu r. 1 I don' t know if Paul knows.
2 But I do know that in the PSAR the condenser ,
3 cooling water system is classified as a Class 1 structure 4 .and system.
5 DR. SilEWMON: Joss, they may indood sediment in, 6 but if they are coating tubos, it is not sediment. Sediment 7 is usually something that comes from gravity, and if you 8 coat all of them, it is coming out of solution.
9 MR. EBERSOLE: They called it sediment.
10 DR. SilEWMON: But that is not consistent with 11 what the answer was.
12 MR. EDERSOLE: I realize that. It is not 13 sedimont in the usual context.
14 I think we can just cut all this short. To look 15 at the overall generic aspect, we have got to look in a 16 genoric context at the potential for sudden plugging, not to 17 say fouling of the uptake structures or all the heat 18 oxchangers, particularly the ones with the finor sized 19 tubes, as a means of choking the heat sink off abruptly in 20 the mannor that we can't repair it fast enough. And of 21 courso if wo loso the ultimato heat sink, we have had it.
22 MR. MICilELSON: May I ask ono question on this?
23 I gather thoro is no component cooling water 24 intormediato loop at Oconoo.
25 MS. FASTIS: Thoro is, but not for this Acti 17ti ntinai. IlitronTrins, INC.
20244717m Nationwkle Omeug m3 % MW,
1930 04 04 47 (o,7 bur 1 particular system.
2 MR. MICilELSON: flow about for bearing cooling and 3 that sort of thing? Is that supplied by a closed cycle or 4 is it open cycle?
5 MS. PASTIS: There is component cooling water, 6 and it cools various things. One of them is the roa'ctor 7 coolant pump seals.
8 MR. MICilELSON: Well, lot me just ask, do the 9 ECCS pumps got their cooling water for their bearings from 10 this water supply or closed cyclo?
11 MS. PASTIS: They got it from this water supply.
12 MR. WILLIS: The ECCS pumps have a separato 13 component cooling system.
14 MR. MICl!ELSON: Whore do they got their cooling 15 water from, from direct service water or closed cycle?
16 MR. WILLIS: It is a different system.
17 MR. MICilELSON: Is it closed cyclo?
18 MR. WILLIS: Closed cycle.
19 MR. MICllELSON: Thank you.
20 MS. PASTIS: You do havo, though, like the 21 omorgency foodwater system. Some of it is from horo, for 22 the oil, like the oil coolors and that kind of thing.
23 MR. EllERSOLE: What cools the diosol enginos?
r 24 MS. PASTIS: They don't have diosol enginos.
25 They havo the Kiwi hydro station. Lake Kiwi does.
Aci!.Fi:niti<Ai. Iliti>oi<Titi<s, INC.
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1930 04 04 48 (m); bur 1 MR. WYLIE: It works off the same water.
2 (Laughter.)
3 MR. EBERSOLE: More copious flows.
4 DR. KERR: liow much more do we nood in that 5 context?
6 MR. EBERSOLE: Woro there any more points on 7 this?
8 I think we have probably closed it out. ,
9 MS. PASTIS: If you are happy. Thon any more 10 questions?
11 (No responso.)
12 MS. PASTIS: Thank you.
13 MR. LANNING: Thank you, llolon.
14 The noxt event involves a boiling water reactor.
15 Mr. Carl Schulton will describo it.
16 (Slido.)
17 MR. Scil 0LTEN: My name in Carl Schulton, the 18 cognizant engincor for the WNP ovent, charactorizod as wator 19 in the ntoam linos.
20 This was a reactor scram on losn of foodwater and 21 ronultant filling of tho vonnel above the stoam linos.
22 floforo I got into the details of the noquenco of 23 the ovont, I would liko to discuna the problems or the 24 counon of thin events.
25 (Slido.)
Acit.17 iniiRAi. Riii>oit riins, INC, 2ia.H7.Um Ntionmde Cmcrge m)4 MM
1930 04 04 49 llhVbur 1 The primary contributors woro personnel operator 2 orror and proceduro errors. The equipment operator 3 incorrectly identified the RCIC system as being tripped on 4 mechanical overspood after the reactor was scrammed 5 manually.
6 The nocond contributor was the control room 7 operators improporly lined up the condensato feedwater 8 syntom for ningle olomont level control, and a contributing 9 problem was administrativo error resulting in the reactor 10 operatora not having available to them in the control room 11 any temporary deviation to the scram proceduron.
12 DR. KERR: What does that mean? Are you going to
\
13 explain?
14 MR. SCllVLTEN: I will discuan that.
15 (Slido.)
16 The potential nafoty nignificanco of thin event 17 in a water hammer scenario; that in, prennuron greator than 10 500 poiq.
19 The initiator was a failed fuso in the foodwater 20 control syntom couning maximum domand from tho foodwater 21 turbino driven pumpn.
22 The foodwater pumpn then tripped on low ouction 23 prennuro. The reactor vunnel bogan to nhrink. The 24 operatora manually nerammed the reactor in anticipation of a n
'd 25 Levol 2 neram.
Arl!I7lil)l:RAl. IllipORil!RS, INC
- o: m u m sai,,,,m ua ,,u, m m , m, e,
1930 04 04 50 13
( ,Jbur 1 At Level 2, both high pressure core spray and 2 RCIC initiated and began injection into the vessel. Also, 3 occurring at Lovel 2 we had an ATWS recirc pump trip and 4 NSSS valve groups 1 through 7 isolation. This gave you an 5 offectivo isolation of the reactor vossol.
6 DR. KERR: What is an ATWS recirculation pump 7 trip?
8 MR. SCl!ULTEN: The recirc pumps add positive 9 reactivity.
10 DR. KERR Oh, I 800. Does the pump always trip 11 when you got a trip?
12 MR. SCilVLTEN: At Level 2 it does.
13 DR. KERR It does not trip on any trip but a 14 Lovel 2 trip?
15 MR. IlODGES : This is Wayne llodges. 11 0 called it 16 that because the purpose of tripping the pump at that lovel 17 is for ATWS protection.
18 DR. KERR: It is a pump trip that trips on any 19 trip?
20 MR. I!ODGES: Except for ATWS protection.
21 DR. KERR There are somo implications if one is 22 having an ATWS horo?
23 MR. SCllOLTEN: No, that is what it is called in 24 tho toch spec, is a Lovel 2 trip.
25 DR. REMICK: Is Lovel 2 a low load trip?
Act -171:i>tinAi. Iliti>oR ri Rs, INC.
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1930 04 04 51 llhVbur 1 MR. SCHULTEN: Yes, a low load trip. There is 2 one other load level.
3 At this point we begin to get our complications.
4 There were three operators involved in the sequence. One ,
3 5 operator failed to properly line up the feedwater condensate 6 system, flow control valve 10 for single element level 7 control.
8 The second operator was stationed to control 9 pressure in the reactor vessel, using the relief valves, and 10 the third operator was getting into dry well cooling 11 recovery procedures.
12 Let me explain this to you. The equipment 13 operator down in the RCIC pump room notified the control 14 room that they had had the RCIC pump trip on mechanical 15 overspeed. This led the operators to believe that they did 16 not have RCIC available to them for both pressure and level 17 control, which would be the preferred mechanism for getting 18 out of the scram.
19 The complication was the operator who misaligned 20 the feedwater condensate system.
21 (Slide.)
22 MR. EllE RSOLE : Do they have a steam driven llPSI?
23 MR. SCllULTEN : Motor driven. l 24 MR. EI3 ERSOLE : So that was available.
{')/
't 25 Go ahead.
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1930 04 04 52 llhVbur 1 MR. SCHULTEN: So what you have now, if you can 2 refer to your slide that I just took off, the RCIC and the 3 HPSI system arc racing one another to fill up the vessel.
4 DR. KERR: What am I supposed to conclude from 5 that slide?
6 MR. SCHULTEN: Nothing yet.
7 DR. KERR: Okay.
8 MR. SCHULTEN: I was going to show you where the 9 valvos were misaligned.
10 DR. KERR: Sure, go ahead.
11 MR. SCHULTEN: You can conclude that it is a 12 complex system.
~ 13 (Laughter.)
14 MR. SCHULTEN: This is flow control valve 10.
15 This is the valve that controls the reactor vessel level, 16 the single element control.
17 The block valves downstream of the high pressure 18 heater valves, ll2A and ll2B are required to be closed, and 19 117A and 117B are required to be open in order for this flow 20 control valve to do its duty to fill the vessel. It would 21 control it to roughly 650 psig, which is the shutoff head f 22 for the bocmter pumps.
23 The operators opened the 117 valves and failed to 24 close the 112 valves.
! )
/ 25 MR. MICHELSON: Which ones are on automatic high Acti-FitorinAt. RiiPon ritas, INC.
M2 347.Um Nationwide Coserage Rx).U6&46
1930 04 04 53 llhVbur 1 level cutoff?
2 MR. SCHULTEN: The booster pumps.
3 MR. MICHELSON: Don't they close the valve as 4 well as trip the pump on high level?
5 MR. SCHULTEN: Maybe I didn't understand your 6 question.
7 MR. MICHELSON: What happens from feedwater 8 overfill? How do you protect against feedwater overfill 9 normally? What prevents the feedwater?
'10 MR. LANNING: The feedwater pumps.
11 MR. MICHELSON: They trip?
12 MR. LANNING: That is right.
13 MR. MICHELSON: No valve operation, just 14 feedwater pump trip?
15 MR. EBERSOLE: That leaves you open to input from 16 the condensate booster pumps, and there is no level control 17 on them.
18 MR. SCHULTEN: Well, this is it. Flow control 19 valve. They take the motor force for the feedwater 20 injection from the booster pumps through that control valve.
21 DR. KERR: Why did the operators misalign the 22 valves? Was it just a mistake? Was the procedure wrong?
23 MR. SCHULTEN: There's two very large switches on 24 the control panel. Those should have been closed.
- 25 DR. KERR: And he had never done this alignment ACE FEDERAL REPORTERS, INC.
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'1930 04 04 54 lhVbur 1 before?
2 MR. SCHULTEN: No, sir, they were cognizant of 3 the procedures. There was no real justification for not 4 having done it. It.was an error.
5 MR. EBERSOLE: On the other hand, isn't there 6 some sort of a catcher, a limit at which they should have.
7 tripped the booster pumps on signal?
8 MR. SCHULTEN: We will get into that. They 9 actually tripped them and they restarted.them.
10 Keeping in mind that they thought that they had 11 successfully lined up the' system for single element level 12 control through the 10 valve. That is where they thought r'
(~)) 13 they were,'but they weren't there.
14 (Slide.)
15 DR. KERR: What is a potential water hammer 16 scenario?
17 MR. SCHULTEN: We characterized.this scenario as 18 potential because it is my understanding that the. relief 19 valves are evaluated to pass something like 200 psi i 20 pressurized water or two-phased flow.
21 DR. KERR: I just don't know what a potential 22 scenario is.
23 MR. SCHULTEN: At the time we drafted the slide, 24 we don't know if there was in fact water hammer. At least I O( / 25 should say there is no evidence of water hammer occurring.
i ACE-FEDERAL REPORTERS, INC.
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1930:05 05 55 lhVbur 1 DR. SHEWMON: There 1"s a potential of pushing 2 water into it and it would have flashed, and that would have 3 been a hammer.
4 DR. KERR: Thank you.
5 MR. SCHULTEN: Right now we have had the RCIC 6 system and the HPSI system fill the vessel to plus 55 7 inches. The steam lines are at about plus 108 inches. We 8 have had the operator lining up the feedwater condensate 9 system incorrectly and making the booster pumps available to 10 pump into this vessel once pressure gets down to around 650 11 psig.
12 The equipment operator thought the RCIC tripped
(~')
'(> 13 on mechanical overspeed. This was the whole thing that 14 caused the. operators to say we have to go to the feedwater 15 and condensate system for our level control.
16 Inventory levels off at or below the main steam 17 . lines, 108 inches. The only source of inventory we have now 18 is the CRD pumps, to put in about 60 gpm. The pressure 19 climbs-to the neighborhood of 880 psi.
20 At this point the operator that is controlling 21 pressure opens two relief valves and inventory passes 22 through the relief valves. It is believed that this was 23 steam.
24 MR. EBERSOLE: You had the high pressure core l'
\ 25 spray?
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1930 05 05 56 llhVbur 1 MR. SCHULTEN: It is a motor driven pump. They 2 had a high level. They don't want to add water. They 3 wanted to reduce inventory and reduce pressure at this 4 point.
5 But you are right. They do have high pressure 6 pumps.
7 MR. EBERSOLE: You said the only inventory makeup 8 potential you had was in the core drive pumps?
9 MR. SCHULTEN: I believe what I said was that the 10 inventory being added at this time was from the CRD pumps.
11 MR. EBERSOLE: I have got you.
12 MR. SCHULTEN: This action by the operator
- 13 reduces water level to approximately 75 inches. The 14 pressure drops to 650 psig, which is the approximate shutoff 15 head for the booster pumps.
16 At this point the booster pumps begin injecting 17 water.
18 MR. EBERSOLE: Did the booster pumps have any 19 level sense?
20 MR. SCHULTEN: Not without flow control valve 10.
21 The vessel overfill into the main steam lines. The 22 operators have no indication of vessel level above plus 55 23 inches.
24 All these numbers are taken off the process 25 computer.
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. . ~ . - .. .
v e ,a
^1930105"05 57-hur 1 MR.-EBERSOLE: They just go bl'ind then?'
'2 MR.-MICHELSON: At what elevation is the main 3- 'steamLline? ,
4- MR. SCHULTEN: 108 inches.
-5. MR. MICHELSON:- Is that-the. bottom of-it?
6 MR. SCHULTEN: .Approximately,~yes.
7 .MR. EBERSOLE: So you"are dumping the main steam 8 -lines full of water?
9 MR. SCHULTEN: At this. point. The reactor-
- 10 pressure is about 650Lpsig. The operators trip lthe' booster
- 11 pumps.
J 12 MR.-EBERSOLE: Are-these' des'igned to operate on-13- full reactor loads?
t' .
. -14 MR. SCHULTEN: It is my understanding'that they
. 15 'are,~up to the_MSIVs.
16 MR. HODGES:- They can support the full water 17 ~ load. That is not the' problem'. The problem is dynamic L 18 loads.
p i 19 MR. EBERSOLE: Is that a general statement? They 20 can always support full water loads?
. 21 MR. HODGES: During refueling they are filling up 22 with water.
t
' 23 MR.'SCHULTEN: You have to keep in mind at this 24 point that the operators are very busy trying to get dry 25 well cooling back. The dry well is heating up rapidly. It ACE FEDERAL REPORTERS, INC.
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,, ___ .,. . _ ._ _.,_. .. _ _. _.~ , _ _ . _ .,_. _ . . . . . - _ . . . _ . _ . . . . _ _ _ _ , _ . , _ _ , . . .
"1930 05 05 58 lhVbur 1 was-initially at something like .1 psi. It was rapidly 2 ' increasing. In 10 minutes it ran,up to 1 psi, and at 1.4 3 psi or thereabouts they got into a situation where they had 4 .tio get into venting procedures.
5 So they_are trying to establish hang-on cooling 6 water.
7 MR. EBERSOLE: Hang-on_ venting. That is 8 interesting.
9 What did they vent? You said they had to get 10 into venting procedures, 11 MR. SCHULTEN: They had to have pressure relief.
12 MR. EBERSOLE: Okay. Pressure relief.
13 MR. MICHELSON: When did they start relieving 14 pressure?
15 MR. SCHULTEN: They never got that high. They 16 established dry well cooling'before they got to the scenario 17 where they would have had to relieve pressure.
18 MR. MICHELSON: In the meantime, the relief valve 19 is open, is that right?
20 MR. LANNING: They were opening the relief valve.
21 The point of this discussion is they were preoccupied by the 22 loss of the cooling function. They were trying to 23 reestablish containment cooling. It came out as that they 24 were seeing high dry well pressure.
O)
\._ 25 They had established level control, they thought, ACE FEDERAL REPORTERS, INC.
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1930 05 05- 59 lhVbur l' but they were preoccupied with the establishment of 2 containment cooling to prevent this containment isolation.
3 MR. MICHELSON: And the high level alarm didn't 4- bother anyone?
5 MR. SCHULTEN: What alarm?
6 MR. MICHELSON: You have a high level alarm on 7 the vessel.
8 MR; LANNING: It didn't. That is right.
9 MR. MICHELSON: It is safety grade, and none of 10 that worked?
11 MR. LANNING: I think they.were just too 12- preoccupied.
rm
(_): 13 MR. MICHELSON: You don't get preoccupied. When 14 an alarm goes off, you have got to clear it or something.
15 MR. SCHULTEN: You can silence it. You don't 16 have to clear it.
17 MR. EBERSOLE: They were racing against the high 18 pressure in containment, weren't they? Had that occurred, 19 it would have made some new evolutions?
i 20 MR. LANNING: It would have made recovery more 21 complicated, yes.
22 MR. SCHULTEN: I don't know why they didn't pay 23 any attention to the vessel level, which is the point of 24 this discussion.
(~h
\/ 25 At this point the booster pumps had been manually ACE FEDERAL REPORTERS, INC.
202-347-3700 Nationwide Coverage 800-336-6M6
1930 05 05 60 llhVbur 1 tripped. The dry well cooling recovery procedures are 2 complete. Essentially what this means is they have restored 3 power to the nonvital bus, which had tripped off at Level 2.
4 The operator opens a relief valve at 850 psig.
5 For the second time inventory passes through the relief 6 valves, causing the level to drop.
7 Now, they are trying to get into -- they still 8 think they have control, single element level control.
9 They haven't determined that the block valves downstream or 10 high pressure heaters are open. They are not trying to 11 equalize the pressure on the inboard MSIVs so they can 12 establish level control using the bypass valves and using 13 the condenser for a heat sink.
14 The MSIV equalization process contributes to a 15 steady pressure decay, from 750 psig and a reactor level of 16 approximately 55 inches.
17 MR. MICHELSON: What is RVS?
18 MR. SCHULTEN: Relief valves. This is a relief 19 valve.
20 MR. MICHELSON: You said the inventory passed 21 through the relief valves.
22 Is that what you meant, that there was water 23 slugging or whatever? Do you know roughly the kind --
24 amounts of water we are talking about in the main steam 25 line, in the main steam header?
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^'1930105:05 :61 lhVburL 11. MR. SCHULTEN: I don't have the details.- I think' 2! it is approximately 200 gallons per inch of reactor vessel.
3" MR.' MICHELSON:
If the bottom of the steam line
'4 is 180 -- I~think you said:you got as high as 1507 .
~
15 ~ MR. LANNING: The bottom water in the steam line.
6 MR. MICHELSON: You would have to fill the steam-.
7 line virtually except 'for the steam bubbles that weren't 8 collapsed yet.
9 MR. LANNING: There are analogies ongoing _with
! 10 respect to that issue.
4 _
11 :MR. MICHELSON: And when you openedJit, you.had i 12 to release slugs. 'So you.are looking-at the tail pipes-on 13 the valves and the valves.themselves to see how they managed 14 it.
4 15 MR. LANNING: That makes this event significant.
16 MR. MICHELSON: 'Yes.
17 MR. SCHULTEN: At the same time they were opening 18 the relief valves they were also draining the water from the 19 steam lines in the drain line.
4
[ 20 MR. EBERSOLE: What containment is this? Mark I 21 or Mark II?
22 MR. SCHULTEN: Mark II.
-23 MR. EBERSOLE: So it has got those long tail i
24 pipes you don't want to knock off?
25 MR. SCHULTEN: Downcomers, uh-huh.
L i ACE FEDERAL REPORTERS, INC.
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, - - - , . ...~ ,, ._. -- -~ -- .. . -_ - , . - - - . _ . . . . - - . _ , . . _ _ . . - . _
1930 05 05 6?
lhVbur 1 Just for calibrating you, the first inventory 2 level off was about plus 20 minutes. The first vessel 3 overfill was about plus 34 after the scram, and now we are 4 down to around plus 102 minutes.
5 We are just about finished.
6 MR. MICHELSON: Did this warrant an AIT?
7 MR. LANNING: We did not perform an AIT.
8 MR. MICHELSON: We have a generic issue, you 9 know, on steam generator overfill, which this is a great 10 test of.
11 MR. ROSSI: My understanding is that this was 12 originally reported to the NRC by phone, and I don't think 13 all the details were there. So the details didn't come on a 14 5072 phone call, and as you know, there are a number of 15 sieves that these events go through within the agency.
16 This particular one was picked up, as I 17 understand it, by AEOD in their review of the LER that had 18 more details. So the agency found out all of the pertinent 19 details on overfilling the vessel, water in the steam lines 20 and all that at the time the LER got reviewed, which was 21 quite a bit later.
22 MR. MICHELSON: That doesn't prevent you from 23 having an AIT.
24 MR. ROSSI: We could still have an AIT.
/ 25 MR. MICHELSON: Or an IIT, if you wish.
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202-347-3700 Nationwide Coverage 800-336-6M6
1930 05 05 63 llkVbur 1 MR. EBERSOLE: Ernie, while you are still there, 2 I am getting a distinct impression here that the boilers are 3 designed to accommodate overfill and completion saturation 4 of the main steam lines, which would include the uptake to 5 the SRVs as a matter of practice. I didn't know that.
6 MR. ROSSI: There are a couple of other people 7 here.
8 I think the situation is that the lines may be 9 designed to support the static water load, but I don't think 10 they have done all the analyses to show that the lines could 11 withstand water hammer or water hammer wouldn't occur or all 12 those kinds of things.
_/ 13 So the plant is not designed for water up the 14 steam lines, even though there are some problems that 15 probably won't occur with water in them, such as the lines 16 won't fall down.
17 Is that a fair assessment?
18 MR. EBERSOLE: The most sensitive aspect of this 19 is that you are going to start waters in the SRVs and knock 20 out some of those oowncomers. Then you are in big trouble.
21 I don't know whether the dynamic analyses of the downcomers 22 accommodate this dynamic loading.
23 MR. HODGES: That problem was looked at, but not 24 for this pressure range. After Three Mile Island there was x 25 a concern that we are getting into problems with the safety ACE FEDERAL REPORTERS, INC.
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1930 05 05 .64 lhVbur 1 relief valves. They were required -- the BWRs in particular 2- were required to go back and look at where they might be 3 expected to have water, either two-phased or water slugs in 4 the steam. lines'and run tests to make sure that the valves
'S and tail pipes could withstand it.
6 .They made arguments that we accepted that it was 7- 'only'likely to occur at low pressure. They ran their tests 8 in about the 250-pound range.
9 MR. EBERSOLE: Interestingly enough, that is when 10 the donut starts to jump up and down. It is the low end of 11 the range where the biggest-dynamic loads take place.
12 MR. HODGES: They did test using steam and then b 13 water.
14 MR. EBERSOLE: That was the root of all the 15 suppression problems in the last ten years if they didn't 16 have a tail end.
17 MR. HODGES: One of the concerns is if you break 18 the tail pipe in the air space you have got problems, and it 19 was demonstrated successfully.
20 MR. EBERSOLE: I don't think you can cut off an 4
21' arbitrary pressure like 250 to 300 pounds. It may be that 22 most severe dynamic loads are below that.
23 MR. HODGES: That was the highest pressure that 24 was tested.
25 MR. MICHELSON: There is going to be a ACE FEDERAL REPORTERS, INC.
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1930 05 05 65 llkVbur 1 subcommittee meeting in August on thermal hydraulics. I am 2 sure this is going to be a subject added to the agenda.
3 MR. EBERSOLE: We are up to two hours now.
4 (Slide.)
5 MR. SCHULTEN: We are almost through.
6 The operators -- the MSIV equalization process is 7 contributing to the steady decay of pressure in the vessel.
8 The operators restart the pumps approximately two hours 9 after the event began. The pump begins injecting at 10 somewhere close to 166 minutes, when the pressure is reduced 11 to 650 psig. This is your final fill-up of the vessel.
12 This is one pump running now.
13 The operators see this as very unusual, that the 14 vessel keeps going up. They look at the panels. They 15 locate the two valves. They say, ah-ha, they should be 16 closed and not open. They close down.
17 There is a three-minute stroke time on those 18 valves. In that three minutes the vessel overfills into the 19 main steam lines.
20 MR. EBERSOLE: So the level system is not blind?
21 MR. MICHELSON: It was probably working fine. I 22 am sure they were just shutting off the alarms.
23 MR. LANNING: It is more than that. Let me try 24 to review the whole event and what we are trying to convey.
- 25 There were a number of operator errors and ACE FEDERAL REPORTERS, INC.
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1930 05 05 66 llhVbur- 1- deficiencies that resulted in this event. One of them was 2 the way they alarmed the system, automatic level control, 3 using.the condensate booster pump. That was an error.
4 As a result -- in addition to -- they were 5 preoccupied by trying to reestablish containment cooling.
6 One thing led to another and cascaded into a number of 7 events that resulted in water in the steam lines.
8 This is the second event at Washington Nuclear 9 Power 2 within the last year.
10 There-are a number of follow-up actions with 11 regard to this event and what is the problem. So it is also 12 important-that we have addressed vessel overfill and steam
) 13 generator overfill in generic issues. Those are ongoing.
14 You know, what we just wanted to highlight to you 15 here is an event involving a BWR that we had assumed in the 16 past that the high level trips in the vessel-level would 17 prevent this kind of event.
18 MR. MICHELSON: That is what the PRA shows. It 19 might become a hot issue again, where we were trying to 20 throw it out because of low probability before.
21 MR. LANNING: It is a low pressure event, and 22 there is some question about the amount of subcooling in 23 this water when it fills the steam line, in addition to the 24 water hamner. They are all related issues in conjunction l; 25 with whether or not there should be a pump trip on the ACE. FEDERAL REPORTERS, INC.
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1930 05 05 67-llhVburL 1 condensate booster pump.
2 There is another question whether or not there 3 should be containment _isolations of containment cooling 4 systems on some of the level indications other than this 5 one.
6 So there are a number of ongoing issues that made
- 7 this event.
8 MR. EBERSOLE: You see, that gets to the punch 9 line, the. reactor effort that you are going to follow up.
6 10 You were already looking at these things. Th'is 11 just came along as a convenient shot in the arm to look at 12 it, as I take it.
) 13 MR. LANNING: It has some very plant specific 14 issues associated'with this event.
15 MR. EBERSOLE: As far as we are concerned, see, 16 we come to the point where we say what are we supposed to 17 do, anything, just watch?
18 MR. MICHELSON: I am a little concerned that an ,
19 event of this significance went so long before the agency 20 realized. One of two things, either the utilities didn't l
21 tell us adequately or we didn't understand when told whether j- 22 AEOD picked it up.
23 That is a little disturbing either way.
24 MR. LANNING: That is extremely disturbing to all l
-) 25 of us. That is one of the follow-up activities the region
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1930 05 05 68 llhVb'ur 1 has. The reports were just not descriptive of the event.
2 MR. MICHELSON: This is Mr. Lewis' kind of thing, 3 that he can look at the regulatory process.
4 DR. KERR: Can I ask, it was apparently almost 5 three hours before the operators realized that a 6 . misalignment had taken place and that this was the same 7 group of operators; it wasn' t a shif t change or anything?
. 8 MR. SCHULTEN: Not to my knowledge.
9 DR. KERR: Finally, something suggested to them 10 to take a look at the board?
11 MR. SCHULTEN: Yes. After they had tripped the 12 booster and then they placed one booster back on and they 13 saw the vessel level wasn't being controlled. They'actually 14 put the booster online at 120 minutes after the initial-3 15 scram. However, it didn't begin injecting until some 20 16 minutes after that or a little bit later.
17 So when they saw the level wasn't being 18 controlled, they switched to the emergency.
DR. REMICK: What time of day was this?
19 20 MR. SCHULTEN: It was in the late afternoon, 21 1940.
22 DR. REMICK: What kind of engineering talent did 23 they have in the control room?
24 MR. SCHULTEN: I don't know, other than the three
( 25 operators, who else was involved.
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1930 05 05 69 llhVbur 1 MR. EBERSOLE: What I keep hearing is that they 2 don't know where the level is. That bothers me, for god's 3 sake.
4 MR. SCHULTEN: As Mr. Lanning said, the 5072s, 5 they had a scram on loss of feedwater and everything 6 happened.
7 MR. LANNING: I think the level indication was 8 available. There is the question of why the operators 9 failed to acknowledge it properly. That is the big 10 question.
11 DR. REMICK: What is the range of that? I 12 thought it covered most of what we have here.
/
- 13 MR. LANNING: It does. That is the speculation, 14 they were too preoccupied.
15 MR. EBERSOLE: That is the essence of a boiler.
16 Where the hell is the level? ;
17 MR. SCHULTEN: It was off scale, plus 55.
18 MR. MICHELSON: At times it went back on scale 19 before it went off scale again. Why didn't we get an alarm?
20 MR. LANNING: I don't have any reason not to 21 think they didn't get the alarm all over again. Every time 22 they depressurized the relief valve they got below the 23 shutoff head of the booster.
24 This is the type of event that warrants, I think, 25 further investigation by the committee, and it is related to ace. FEDERAL REPORTERS, INC.
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1930 05 05 70 llhVbur 1 other issues.
2 So we would like to go forward, if we can, to the 3 next event.
4 MR. EBERSOLE: I was just going to say one other 5 thing. Is there any thought in your mind that there is a 6 design deficiency here rather than just procedural errors?
7 MR. LANNINC: I Lhink some thought could be given 8 to maintaining or using the condensate booster pump for the 9 level control in this kind of situation.
10 MR. MICHELSON: Leaving the thought, look at the 11 PRAs and find out why they missed. Why was this really 12 missed?
j 13 Because they are using PRAs heavily in making 14 that steam generator overfill argument.
15 DR. KERR: Wait a minute. Does this plant have a 16 steam generator?
17 MR. MICHELSON: No,. The reactor vessel level is 18 part of the steam generator. It is an issue of water in the 19 steam line.
20 DR. KERR: But since there is no steam generator, .
21 why is it an issue as to steam generator?
22 MR. MICHELSON: The issue is called steam 23 generator overfill. The issue includes BWR reactor vessel 24 overfill.
25 DR. SHEWMON: It really should be called steam ACE FEDERAL REPORTERS, INC.
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1930 06 06 71 llhVbur 1 line fill.
2 MR. EBERSOLE: Is that about it on this?
3 MR. SCHULTEN: Yes, sir.
4 If you would like, I have diagrams.
5 DR. SIESS: Is this the type of event you could 6 put on a simulator?
7 MR. LANNING: I think so.
8 DR. SIESS: Is it the type of event that is on a 9 simulator? Is it a frequent enough transient that people 10 have been trained in it?
11 You are telling me that so many things happened 12 at once that they missed something.
_- 13 MR. ROSSI: I think one of the keys was that they 14 lined up a system incorrectly. They can probably do that 15 on a simulator, but I don't think normally this particular 16 transient would be part of the training.
17 They simulate certain kinds of misalignments, 18 operator errors, and equipment failures. They don't cover 19 every single one on the simulator.
20 DR. SHEWMON: Presumably it will be.
21 DR. SIESS: They didn't watch water level.
22 MR. ROSSI: That was the key to it. They were 23 preoccupied.
24 DR. SIESS: Why didn't they watch water level?
?
25 They are trying to see what they are doing instead of ACE FEDERAL REPORTERS, INC.
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r 1930 06 06 72 lhVbur 1 looking at the water level. That is pretty interesting.
2 MR. ROSSI: That could be done. We could go 3 back, I. guess, to another simulator with another plant crew 4 and run through the event.
5 _DR. SIESS: It is hard to say that the people in 6 there were just stupid. There is probably a reason, and if 7 there is a reason you could fix it. You are not going to 8 fix the plant. You have got to fix the people.
9 MR. EBERSOLE: Bill, at this point in the 10 schedule we are entitled to a break.
11 DR. KERR: Then let's take one.
12 (Recess.)
'O 13 MR. EBERSOLE: Mr. Lanning, you can proceed.
\_/
14 MR. LANNING: The next and last presentation will 15 talk to the results of an augmented inspection team activity 16- at Diablo Canyon involving loss of RHR.
17 This was a very interesting event. There was a 18 lot of interesting issues associated with it.
19 I propose that Warren Lyon give you a brief 20 overview of the event and a summary of the issues related.to 21 this event and also RHR in general.
22 I believe we can complete everything within the 23 next 30 minutes.
24 Warren?
O)
\- 25 MR. REED: You call it loss of RHR, but really it ACE FEDERAL REPORTERS, INC.
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1930 06 06 73 llhVbur 1 is a loss of shutdown cooling?
2 MR. LANNING: It is a loss of shutdown cooling, 3 that is right.
4 MR. REED: It is the same system, but you use 5 different words for the same system.
6 MR. EBERSOLE: Let me invite the committee to go 7 back down to the big book and memorize those shutdown modes.
8 We are in the last two of those, 5 and 6.
9 DR. KERR: At the same time we are listening to 10 this important presentation?
11 MR. EBERSOLE: You just need to nail them into 12 your head because they get significant.
_ 13 (Slide.)
14 MR. LYON: As Wayne said, there is a lot of 15 interesting things here. Some of these are of sufficient 16 interest and immediate impact that we contacted plants by 17 telephone when we learned that they were going to be in this 18 mode of operation.
19 The event itself -- and I am going to cover the 20 event itself very quickly initially -- is important not for 21 what happened at Diablo but for what it taught us.
22 Really, the things it has taught us fall into two 23 categories. There is the category of things that we already 24 knew that it brought into focus, and there are many of 25 those, and there is the category of things that we had no ACE-FEDERAL REPORTERS, INC.
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1930 06 06 74 llkVbur 1 more idea than the man in the moon were going on. It is 2 those that I will go into a little bit toward the end of my 3 discussion.
4 Because there were so many things involved, so 5 many topics, I am not even going to attempt to cover them 6 all in this presentation. I am going to highlight a couple 7 of them for you. Then we can range in the discussion in any 8 direction that you would like.
9 Initially, I will ask that you hold the questions 10 until we get into a discussion of some of the phenomena.
11 Then we will just open it up, and we can go in any direction 12 that you people would prefer.
_ 13 (Slide.)
14 The plant itself is a Westinghouse four-loop 15 plant. They had been shut down for seven days. They had 16 lowered the water level to roughly the middle of the hot and 17 cold leg elevations.
18 As is usual in Mode 5, the containment equipment 19 hatch was removed. There were a number of other 20 penetrations open. RilR was in operation. The reactor 21 vessel head had not been removed.
22 As is typical in refueling kinds of situations, a 23 number of tests were going on. In one test there was a 24 failure to isolate a line prior to its being drained, and 1 25 through a series of steps that led to a lowering of the RCS ACE FEDERAI. REPORTERS, INC.
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1930 06 06 75 llkVbur 1 inventory, a lowering of the water level, and the RHR pump 2 current started misbehaving, or behaving erratically if you 3 will.
4 RHR was turned off, and it was off for 85 5 minutes.
6 MR. REED: On your initiator --
7 MR. LYON: If I may, please, I think it very 8 important that we kind of fly through the initial so that we 9 get into the important phenomena, and then we can get into 10 wherever we would like to go.
11 (Slide.)
12 During this 85 minutes, the plant got into a 13 boiling situation within about half an hour. They violated 14 tech specs at about 20 minutes when they got within -- I 15 believe it is 10 degrees Fahrenheit of boiling. They boiled 16 for the remainder of that 85 minutes.
17 But the plant never was really in any danger.
18 The steam generator secondary sides were full, and toward 19 the end of the event they were operating in a reflux mode of 20 condensation.
21 And when we take a look at the amount of 22 inventory in those steam generators, the degree of tightness 23 of the reactor coolant system, that plant could have stayed 24 in that condition for over a day with no actions on the part 25 of anyone, and if nothing else happened there would have ACE-FEDERAL REPORTERS, INC.
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1930 06 06 76 llkVbur 1 been no problem.
2 And there were no radioactive releases associated 3 with it for practical purposes, but as I said when I first 4 started, there are many lessons learned.
5 We believe a large number of these are generic 6 and probably all are applicable to at least some plants.
7 (Slide.)
8 With that bit of an introduction, let me just 9 show you a couple other things that are new. Some shouldn't 10 be, and in hindsight they are pretty obvious, but that are 11 new that came out of this event.
12 They were operating, taking RHR suction off of xJ 13 the loop 4 hot leg that was going through the RHR system, 14 and the water was being returned to all four cold legs.
15 MR. MICHELSON: Show the water level.
16 MR. LYON: They were operating at roughly mid-17 loop. So the water level is essentially like this.
18 One of the first things that we asked them when I 19 got out there and we learned what was going on was what is 20 the level difference between here and here because this is 21 the point of interest. This is where you are going to start 22 to form a vortex and ingest air.
23 Nobody thought of it. They said, hey, the flow 24 areas are so large there's no difference.
I_) 25 Well, would you calculate it for us?
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t 1930 06 06 77 llhVbur 1 Sure. ,
2 We ended up a two-inch difference between here 3 and here simply because one flows through the resistance by 4 way of gravity. Two inches is not very much. .It is 5 interesting, however.
6 Then we asked, well, you are taking your 7 instrument water leg tap off the bottom of the loop 4 8 crossover pipe here, which comes up like so, and you are 9 taking the air side measurement off the-top of the 10 pressurizer.
11 We asked, well, the water comes down and it does 12 this, and of course in this direction it can flow, in this 13 direction it can't flow.
14 So because of the momentum effect, we asked, 15 well, what kind of an increase do you get over here simply 16 because the water can go this way but it can't go this way?
17 They said one inch.
18 Then they came up with one.
19 MR. MICHELSON: At what flow rate?
h 20 MR. LYON: 3000 gpm.
21 Then they came up with one. They are ingesting 22 air over here, and at 3000 gpm you can ingest several 4
23 percent air, and the pump never shows it. The current is 24 nice and steady. The flow rate looks good.
( 25 That air circulates through the system, and that Ace FEDERAL REPORTERS, INC.
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1930 06 06 78 llhVbur 1 air comes in over here. Then the air is now trapped in this 2 region, and it has to bleed back over to the point where it 3 is being sucked away.
4 The only real path is something like this, 5 through the events that are associated with head cooling 6 during power operations and through gaps associated with the 7 hot leg.
8 That is a highly plant dependent parameter. It 9 can, however, introduce another pressure effect that pushes 10 down on the liquid leg from this side and is felt on the 11 liquid leg of the instrumentation.
12 So we are talking on the order of three inches
'_/ 13 plus. Right off the bat then we have three inches plus of 14 error built into the instrumentation that no one had thought 15 of, and I have talked with several plants. Not a one of 16 them has looked at this.
17 That doesn't say no one has. It just says the 18 plants I have talked with have not.
19 It is very interesting to take that three inches 20 and see what kind of elevations we are talking about .
21 At Diablo the centerline of the pipe is at plant 22 elevation 107 feet, 0 inches. Vortexing, we are told post-23 ovent -- this is post-event now -- vortexing initiates at 24 107 feet, 5.5 inches. Vortexing is fully developed at 107
' _> 25 feet, 3.5 inches.
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1930 06 06 79 llkVbur 1 Where were they operating the plant? Their /
2 procedures said don't go below 107 feet, 3 inches or 107 3 feet, 0 inches, depending where you read. 1 4 So they are already operating the plant according 5 to the procedures at a level below where vortexing is fully 6 developed, and in fact prior to the event they lower the 7 level to 107 feet, 0 at one point.
8 Previously, during the day they had been as low 9 as 106 feet, 6 inches, where they had RHR pump current 10 erratic indications. They went back up to 106 feet, 10 11 inches, and the current indications went away.
12 Where were they when they lost it? 107 feet, 4 J i 13 inches.
14 And there a lot of things that factor into why 15 these levels are swinging all over the place that I could go 16 into later if you want me to. But let me come back to this.
17 Vortexing initiates 107 feet, 5.5 inches, fully developed, 18 107 feet, 3.5 inches.
19 To drain the plant down we have to pass air 20 through here so that the air can get up into the steam 21 generator tubes and allow them to drain. The top of the 22 surge line leading to the pressurizer is at elevation 107 23 feet, 5.75 inches, and that is the path that they ordinarily 24 use to pass air into the steam generators so that the tubes
_) 25 will drain.
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'h 1930:06 06 51 ; 80 bur: 1 So t[ hey have to go below 107 feet, 5.75 inches in
.2 order to drain the~ tubes, and vortexing in this plant i 3 ' initiates at 107. feet, 5.5. inches.
4 And'on top of my instrument errors, I already 5 have a bias of 3 inches that no one knows about.
6 Well, that is one thing that jumped out at us 7f that we found rather. interesting.
8- People generally, in my opinion, look at these i.
9' situations. They think it is a very straightforward thing.
10 No one has' really' thought to look at the dynamic behavior of
~
, - ll the basic: instrumentation. That is one of the few pieces of 12' instrumentation one has available.
-1$ - DR. LEWIS: When you say no one has thought, you 14- mean.no one'in the plant has thought to?
. 15- MR.- LYON:- No one at the plant, and to my 16 . knowledge, I' haven't-seen any treatment's of the dynamics of 17 the reactor, coolant. system and the interactions with the 18: -instrumentation.
- 19. That doesn't say it doesn't exist. I said I 20 haven't seen it. I am not aware of it.
21 DR. LEWIS: There have been many ACRS letters about that.
.23 MR. LYON: Now, let me just throw one more
- 24. phenomenon at you here.
,5 - (Slide.)
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,llhVbur- l' I can throw in a couple of wrinkles. People ~ talk 2 about we have got such-and'such an amount of time from loss.
3 of RHR until-we start'getting into a core damage situation.
4 One thing we'have-learned is be careful of that, folks.
5 '
We start, we-have a liquid level that looks about 6 like this throughout the system.
7 At Diablo they started. boiling the core at about 8 30 minutes. ,At 45 minutes boiling was fully developed. The 9 metal up through here was getting pretty well heated up.
10 Steam was coming out here.
- 11. By the timeLwe reached an hour we were up in the 12 steam generators and condensing with the condensate running
~)
w_/ 13 back, standard run of the mill reflux mode except for one
-14 ' thing. .The^ pressure in the' reactor coolant system at the 15 time this was occurring was.somewhere around, say, 7 to 10 16, or so pounds per square inch. That was unanticipated-and EU- =17; unanalyzed, and it has some rather-interesting implications.
d.J i 18 The reason the pressure went.up rather than y '3' 19 staying simply at one atmorel tre, which is what you would
. t 20 i oxpect with cold water c. c . the steam generator J2 1; y secondaries, is you have got a lot of air in this 22 essentially closed reactor coolant system. As the steam 23 goes off in this direction, it carries the air with it, and g;f
,. n 24 as' the' . steam condenses and the condensate returns, -the air N/ 25 remains behind.
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1930 06 06 82 lkVbur 1 So in effect you are filling these tubes up with 2 air. In order for the steam to get to a condensing surface, 3 it has got to build pressure and it will build pressure 4 until it finds a condensing surface, and we estimate that 5 pressure was in this range.
6 Now, let's look at the implications of that. Let 7 me throw out two things for you as possibilities.
8 One typically goes to mid-loop operation rather 9 quicklyfrompowercherationifyouhavereactorcoolant 10 pump problems and you need to open the pumps up to some kind 11 of repair, or one would do the same thing in a plant that 12 has loop isolation valves.
13 If you open an opening in the cold leg with air 14 and the head still on, which could be the case that I was 15 just discussing -- and in fact happened in two plants during 16 May and we called them both -- you would start this pressure 17 buildup situation on a loss of RHR situation because the 18 steam has nowhere to go and it is going to build pressure 19 until it starts condensing.
20 As it builds, that water level is going to start 21 dropping both here and here, and the water will flow right 22 out the break.
23 24 25 ACE FEDERAL REPORTERS, INC.
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1930 07 07 83 lhVbur- 1 So as you start building pressure, as you are 12 boiling,'you start forcing water right out the opening. To:
my knowledge, no one has analyzed this ortconsidered it.
4 When we. posed the situation to one plant, they 5 kind of scratched their heads and they did the prudent 6 thing. They closed out~ containment.
7 I might add that the Diablo Canyon folks also 8 closed up containment while they were in the mid-loop 9 condition.
10 There_were-a lot of other crazy things going.on.
11 Let me throw you one more. Then we will kind of open it up 12 for discussion.
O DR.-KERR:
L(_) 13 What does closing containment have to 14 do with decreasing the core damage? ,
15 MR. LYON: Not a thing.
16 But if you are in a situation which we consider 17 to be very challenging to the operators and it is perhaps a 18 higher risk condition than one would have if you have been 19 sitting for a month and you have got the core flooded up so 20 it is full again, it simply says we will do the prudent 21 thing and if we do get in trouble we will have the i
22 containment closed up so that people are protected. It is 23 not an easy task to put a 25-foot diameter equipment hatch
( 24 back on and close up some other things that have been 25 permanently taken apart, for example.
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-1930107 07 84 lhVbur' l' DR. KERR:- I would have. thought the first 2 reaction would be to try to protect the core rather than to
'3 try to put together something that-would -- well, it could l4 protect- it if the core got damaged, but maybe they did both.
5 MR. EBERSOLE: It would take separate teams, at 6 any rate.
7 MR. LYON: The point is well-taken, and of course 8 one would put a major effort into making sure you didn't get 9 into a problem. But the thing that has been happening here 10 is we have known about these problems for years, some of 11 them.
12 Hal over here has been studying some of that. We n(-) 13 put out information notices. The industry has done a lot of
- . 14 work in that area. Yet these loss of RHR events continue-to-
' l!F occur, and we really haven't solved the problem, and Diablo, 16 if it did nothing else, has certainly flagged that it'is 17 time to handle the problem.
18 Let me throw you another interesting phenomenon.
19 The operators didn't trust their level instrumentation.
20 (Slide.)
21' One of the operators told us during interviews 22 that if they perturbed the system it would take four hours 23 to a full shift for the level instrumentation to steady down 24 after they perturbed the system. Yet this is a key item N- 25 that they are looking at for the control of the plant.
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1930 07 07 85
( Ibur 1 As a result of starting to ask why, a postulate 2 has come up that, well, when we are ingesting air, that air 3 could be flowing throughout the RHR system. Some of it may 4 become trapped in the RHR system and allow water previously 5 in the RHR system to move to the reactor coolant system or, 6 conversely, if you started ingesting a little less air then 7 some of the previous air might be moved out of the RHR 8 system and replaced by water from the reactor coolant 9 system.
10 No one ever thought about that kind of thing.
11 How does it happen?
12 Well, taking the Diablo plant, you have one RHR D)
(- 13 pump operating. It is exhausted into an eight-inch line.
14 It goes through a T, through two heat exchangers, and then 15 each of those two eight-inch lines separates into two six-16 inch lines. So in effect then I have flow in a six-inch 17 line, four of them, going to the cold leg water return.
18 That flow then comes down and goes into a 10-inch 19 accumulator line. Then that comes down and goes into the 20 cold leg, about 27 inches, 29, somewhere in that ballpark.
21 One can postulate that this guy is ordinarily 22 full and this is probably close to full. Now, if I start 23 carrying air into the RHR system, that air when it goes 24 through the pump will be pushed up to about 120 psi, and t'h
(_) 25 then as it travels through the system it will tend to ACE FEDERAL REPORTERS, INC.
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86 j'h sm ,Jbur 1 expand..
2 If'I start adding air, I could postulate that.I 3 start getting air here and the water that was previously 4 here would dump down into the reactor coolant system, and as 5 more_and.more air comes in this. kind of thing might occur.
6 Similarly,-we could have this kind of thing 7 occurring. There are a number of places throughout the RHR 8 system where this kind of behavior may be feasible. We 9 haven't got-analyses yet that tell us whether this is s 4
10- reasonable or not.
11 What we do have is a situation in which the plant 12 was operating. We have this off the plant recorder and a 13 plot of level versus time, and we are in a situation where 14 things are pretty steady, and then the operators reduced
+
15 level.
16 Lo and behold, the level came back up. So they 17 took some more inventory out. The level came back up. A 18 saw-tooth curve repeated a number of times.
19 Similarly, if you are running along steady and 20 you add inventory, then close up the reactor coolant system, 21 RHR systems combined, the level goes back down. '
22 Terrific. No wonder the operators don't trust 23 it. No one ever looked at why it behaved this way.
l 24 These are some of the kinds of things that are 12 5 coming out of the Diablo event that I consider to be new.
' /\CE. FEDERAL REPORTERS, INC.
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i c1930)07:07 87 lhVbur 1 They.addIto the previously recognized kinds of things ~.
2 Of conducting various tests'while you are at mid-
-3 loop, a rather critical condition; having not considered 4 that, well, if one gets into trouble, what is the condition 5 of containment. . There were 'all kinds of maintenance-6 possibilities, training, analyses.- I could go on for-quite t
7 a while.
E 8 DR. KERR: How about another five minutes?
9 (Laughter.)
'10 MR. REED: When do I get to launch my-barrage of 11' questions?
12 MR. LYON: Go.
. 13 DR. KERR: Right now.
- 14 MR. REED: Are you ready?
15 MR. LYON: I wanted to get into this.
16 MR. REED: This shutdown cooling event doesn't 17 surprise me at all. What surprises me is how procedurally 18 the plant got into the situation.
- . 19 First of all, the whole lead-up to the situation 20 was the elimination of stop valves that were installed at 21 Yankee Rowe and Haddam and then the next vintage of plants 22 did away with stop valves in the loops.
23 When you do away with stop valves, you set 24 yourself up for a geometry situation; that is, in order to 25 remove the. steam generator manways, you have got to go to ACE FEDERAL REPORTERS, INC.
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88 llhVbur- 1 something like half-pipe because you have certain elevations 2 all precalculated to set the steam generators at so you can 3 get-access without stop valves into the steam generators.
4 Okay. Half-pipe is not a difficult place to 5 arrive at because along with eliminating stop valves-the 6 designers decided to eliminate steam generator water box 7 vents. However, they still exist on such plants as Rowe, 8 Haddam, Point Beach, and so on and so forth.
9 .DR. KERR: We are still waiting for the question 10 ~ MR. REED: So what this is, is designed like 11 topsy,' poor instrumentation, poor realization, and 12 procedural error.
/G AJ 13 Why did they get into this condition with the 14 head still bolted on?' What for?
- 15. I don't understand this. Ordinarily, the only 16 reason you go here -- if the head is still on, you want to 17 leave the water level as high as possible; namely, right up-18- close to the flange. I don't understand why their 19 procedures are written to get into this.
20 MR. LYON: To answer your question, they were in
, 21 a refueling outage. They were lowering level, so that they 22 could do steam generator tube eddy current testing. They 23 were then going to flood back up, remove the head, and do 24 their refueling while they continued with the steam i (o_) 25 generator work.
t ACE FEDERAL REPORTERS, INC.
202-347-3700 Nationwide Coverage 800-336-6646
1930 07 07 89 hbur 1 So it is really they are trying to do two things 2 at once and save themselves some time.
3 MR. REED: They had decided to do steam generator 4 work first.
5 MR. LYON: They decided to set the situation up 6 so they could do the work first because if they lowered the 7 level later on they would have themselves some pretty good 8 dose rates.
9 MR. REED: The thing that bothers me is one 10 design omission which should never have taken place is the j 11 removal of steam generator water box vents. If you had the 12 vents, you can put nitrogen in and drop the water out of the 13 hair pins, and you know where your water levels are better, 14 and you don't worry about blockage or water hang-up from the 15 steam generators.
16 Also, one must realize that the instrumentation 17 has been created sort of backwards and like topsy on water 18 level, and half pipe really means you had better not get to 19 half-pipe, you had better stay somewhere above that, and it 20 is a very inaccurate reading. You really don't know why you 21 are on there.
22 Little things, such as water must flow downhill, 23 and so on and so forth.
24 So I really think we have had many of these L 25 events, loss of shutdown cooling. They are a little bit ACE FEDERAL REPORTERS, INC.
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llhVburl 1 plant ~ specific, and they are operationally complicated.. _
~2 You have done a lot of calculations here, and I 3' don't even. trust.your three inches and one inches-and other T4 ' finches.
5 MR.'LYON: I don't either, not yet.
6 MR. REED:- I think you have to leave a good plus,
- 7. good margin. When you say. half-pipe, you should be just as 8 high as you can be and you should be looking at your 9- shutdown cooling system to:see whether it is suffering.
10 MR. LYON: And you should also be considering.
11 . specialized kinds of things- such as should I .really be 12 operating the RHR at.that kind of a flow rate or should.I
(' .
T . 13. drop back, so that vortexing and air ingestion are less of a 14- problem..
15 We really haven't looked-at.some of those things, 16: and that is another couple of messages coming out of this.
17 i Your selection of the stop valve I thought was an 18 interesting one because one of the plants that we contacted 19 because of this situation was a plant that had a stop valve
. 20 problem, and they brought that thing screaming on down in
. - 21 power and cooldown so they could fix that and get back 22 online.
23 And we were concerned with what we had learned 24- from Diablo. So we shared it with those plant people so 4
. 25 they would be very aware of some of these kinds of things
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1930 07 07~ -91 hbur' 1 just . in ' c'ase'.
2 MR. REED: ' Because they ordinarily wouldn't bring 3- their water level down very low in the vessel. They would 4 keep it'up. Or they wouldn't go-to half-pipe.
-5 MR. LYON: .They had to bring it down below the 6 level of the stop valves in order to. bring it down to work 7- on it.
8: MR. EBERSOLE: We are coming up to the endpoint 9 of this discussion at quarter to. .I would like to auk the 10 committee to ask-any'other pertinent questions to this 11 particular topic here that they would care to at this time.
12 Are there any others?
( 13 (No response.)
14 MR. .EBERSOLE : If not, I would like to say that 15 you have a case in front of you where you still-have the 16 reactor vessel head on.
17 I presume in your subsequent investigation you 18 will look at the case where you have just taken it off in 19 the shortest possible time you could have, and you are faced 20 with direct open boiling and venting to containment as a 21 result of loss of power, or whatever, which could be very 22 awkward, too.
23 MR. LYON: By the way, the Diablo situation would 24 have been a boiling into containment because the steam 25 generator secondary manways had been removed. So the steam ACE FEDERAL REPORTERS, INC.
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1930 07 07 92
( ,; bur 1 from the steam generators would have gone into containment.
2 MR. EBERSOLE: If that were to occur, say, at 3 three or four days or the most rapid way, you could take the 4 head off, no matter where you get the water, which would 5 have to be something like a fire system, if you had an AC 6 power failure for that case.
7 So I presume this investigation will go into-the 8 PRA category, where whatever contributions we have to core 9 melt will be recognized in subsequent PRAs.
10 I am just saying that and asking you now to tell 11 what your follow-up is.
12 MR. REED: Jesse, let me make a point. If you e3
() 13 have got the head off, you have opened up the coupling to 14 the spent fuel pit, and you have massive amounts of water in 15 the refueling cavity, in the spent fuel pit. So I wouldn't 16 worry about it.
17 MR. MICHELSON: It depends on the stage. There 18 is an intermediate time.
19 MR. REED: Well, the procedures should be 20 developed that just as soon as the head comes up the water 21 is already coupled together. Otherwise, you don't have 22 shielding.
23 MR. MICHELSON: Detensioning and getting the head 24 off takes time.
O>
\- 25 MR. EBERSOLE: My impression is also at this time ACE-FEDERAL REPORTERS, INC.
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1930 07 07 93 llh/ bur 1 there is very little regulatory interest in this shutdown 2 mode 4 and 5 in the context of formalities, and you get a 3 tie-on to tubing and plastic pipes and everything else all 4 over the place.
5 MR. LYON: I believe that is going to change.
6 (Slide.)
7 That is part of the -- I believe -- importance of 8 what Diablo has taught us. In the very large number of 9 potential issues and real issues that have been raised, I am 10 glad you said something about the follow-on because there is 11 a draft 50.54(f) letter which has been prepared and sent to 12 CRGR. We have a meeting scheduled on June 10th with them.
x_ 13 The intent of that 50.54(f) letter is to 14 essentially establish communication with all PWR licensees 15 regarding all of the kinds of things which contribute to the 16 issues that we have raised. Then of course we will be 17 following up with that.
18 There, also, by way of background information is 19 an AIT report which will be out within another, I would 20 estimate, two to three weeks. This is a NUREG report which 21 covers the work at Diablo Canyon and goes into a number of l 22 the kinds of issues that we have recognized.
23 DR. KERR: Can we have copies of the draft 50.54 24 letter so we can see the issues?
l
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, 25 MR. LYON: I think that could be arranged. Right ACE FEDERAI. REPORTERS, INC.
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1930 07 07 94 llhVbur 1 now it, of course, represents a working document that is not 2 in final form.
3 DR. KERR: I recognize that.
4 MR. LYON: But I am sure that can be arranged.
5 DR. KERR: Unless there's some reason for your 6 not wanting it to see the light of day, it would be helpful 7 to us.
8 MR. MICHELSON: One question. Why limit it to 9 PWRs? Don't you think boilers can't get into some kinds of 10 difficulties in the same mode of operation?
11 MR. LYON: Well, I am going to bounce that one 12 over to Wayne because my knowledge of boilers is very 13 limited.
14 Wayne and I have discussed this. It is all 15 yours.
16 MR. HODGES: I am not aware of any particular 17 situation where they get into the same type of thing.
18 MR. MICHELSON: Not with the level, but they can 19 go through a similar operation and you go through a period 20 of time when they are vulnerable as you loosen the head and 21 you get all the paraphernalia ready so that you can even let 22 water in to the area above the head.
23 Certainly, it is not free from potential hazards.
24 Therefore, I would expect that you are going to look at it.
25 MR. HODGES: I think the level of concern is much ACE I7EDERAL REvonTEas, INC.
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1930 08 08 95 llhVbur 1 lower, though. Also, if it goes for a long time, you have 2 got no real problem here. You have got low decay heat. Why 3 worry about it in the situation you have to go to scram the 4 reactor, and that sort of thing?
5 But this is a situation where you may have 6 auditing systems out for maintenance, you have got the level 7 drain down. As a consequence of what you are doing, you 8 ingest air into the RHR pumps and make them inoperable.
9 MR. MICHELSON: All of w' hat you said applies to 10 boilers as well, the same situation, same problem. You can 11 also get an air ingestion during that period of time, too.
12 But there are some other things at work in a 13 boiler, I realize.
14 Are you really going to look at boilers, or have 15 you written them off?
16 MR. HODGES: At this point we have been 17 concentrating on the two-tube steam generator plants.
18 MR. EBERSOLE: Boilers do have a problem, though.
19 I recall looking at a transient heat-up of the liner on the 20 fuel pools, and it turns out that steel just buckles like 21 crazy because it has got AP concrete around it and pinned to 22 it. You might strip it. You have got a tremendous mass.
23 But the concept of open boiling I think has to be 24 looked at as a possible mode during the loss of AC power 25 during shutdowns.
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1930 08 08 96 llhVbur 1 MR. HODGES: There is no question in a boiler if 2 you get to the situation of long term station blackout. We 3 are not trying to say that.
4 But there is sufficient inventory that you would 5 expect that you would have lots of time to do that.
6 MR. EBERSOLE: Bill, at this point we are 7 supposed to go into a period now of about 10 minutes to 8 reflect on the worth of this.
9 Go ahead.
10 DR. KERR: In the first place, do we have more 11 questions?
12 DR. LEWIS: I have one more question, if I may.
13 Could you remind me what is meant by vortexing?
14 MR. LYON: Certainly. As you are sucking water 15 into the RHR suction line, the water begins to swirl and 16 forms the traditional sort of cone shape.
17 DR. LEWIS: So it is the formation of a vortex at 18 the inlet to a pipe?
19 MR. LYON: And the air blow drop line comes off 20 ossentially at the bottom, but it is at a 45 degree angle to 21 try to minimize this effect.
22 DR. LEWIS: Okay. So given that definition of 23 vortexing, why is there -- I would think that the critical 24 level for vortexing would be a function both of the water 1' 25 level and of the rate of drain of water.
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1930 08 08 97 llhVbur 1 MR. LYON: Absolutely correct.
2 DR. LEWIS: It says here that in many places that 3 there is a critical level for vortexing, and it doesn't 4 mention the rate of flow.
5 Why is that?
6 MR. LYON: In many instances there will be a 7 technical specification limitation that says that we will 8 have flow rate above a particular value. So the plants 9 will operate according to that technical specification.
10 DR. LEWIS: But the critical level for vortexing 11 will depend on what the flow rate is even above that level?
12 MR. LYON: I believe Diablo's tech specs have o
13 3000 gpm. That is where they would be operating.
14 DR. LEWIS: But that is a boundary rate. I am 15 trying to understand why the report refers to a critical 16 level. There is a critical level at that boundary rate.
17 But if you were drawing water at a higher level, 18 the level for vortexing would be higher?
19 MR. LYON: That is correct. That is why I 20 suggested that one of the things that we will be looking 21 into is the possibility of running the RHR system at a lower 22 flow rate during mid-loop operation so that there is more 23 margin before you start vortexing.
24 DR. LEWIS: I am trying to understand whether the g
/ 25 instructions to the operators speak of a critical level for ace-FEDERAL REPORTERS, INC.
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1930 08 08 98 llhVbur 1 vortexing or they speak of a level which is variable as a 2 function of the flow rate.
3 MR. LYON: The procedures that I am familiar with 4 -- and I use the word " procedures" loosely because, very 5 frankly, I am not aware of a really good set of procedures 6 to operate in this mode -- but the procedures with which I 7 have some familiarity only give them a level and they don't 8 go into the variations with respect to flow at all.
9 DR. LCWIS: But that is critical.
10 MR. LYON: And one of the things that came out of 11 Diablo was that vortexing initiated at a level significantly 12 higher than they had thought was the case.
7-13 DR. LEWIS: Well, I am trying to understand why 14 they are focusing on the level itdependently of the flow 15 rate. It says that throughout here.
16 MR. LYON: Because they ordinarily will operate 17 at a fixed flow rate or something similar.
18 MR. EBERSOLE: It may be that they don't have 19 modulating valves.
20 MR. MICHELSON: It may be there are pump 21 limitations, too. You have to have certain minimun flows in 22 the pumps.
23 DR. KERR: One might infer from Dr. Lewis' 24 comments that this is going to be examined. Maybe we ought 25 to say something about flow rate.
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1930 08 08 99 1 llhVbur 1 MR. LYON: We know they can restrict flow because 2 they do it sometimes.
3 DR. LEWIS: I have the impression that the NRC 4 itself is focusing independently on level and flow rate. In 5 the information notice it certainly mentions the level for 6 vortexing.
7 I just think you ought to be more careful and 8 also, just as a comment, it is not so that nobody has 9 thought of the dynamic effects on these pseudo-water level 10 indicators. There is a long history.
11 MR. REED: You made the statement that the Diablo 12 Canyon shutdown cooling line takes off at a 45-degree angle?
13 MR. LYON: That is correct.
14 MR. REED: You had better check that against all 15 other plants, then, because as far as I know, all others 16 that I know of come exactly off the bottom straight.
17 Now, maybe that is part of your problem.
18 MR. LYON: I can assure you Diablo does that 19 because I have been there.
20 MR. REED: Check the other plants and find out if 21 any other plant is made that way. That sounds strange to 22 me.
23 DR. REMICK: Why are you choosing the 50.54(f) 24 letter? Is there something that you want all the licensees
() 25 to respond to that you are considering 50.54(f)? Why that Aci!-FEDERAL. REPORTERS, INC.
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'1930:08 08 100 llhVbur 1 means of communication?
2 MR. HODGES: We considered several options.
3 Obviously, we have already put.out an information notice.
-4 This is what has happened. We felt'that something more was 5 needed. The other options were basically to issue an. order 6 to do something.
7' We felt it more appropriate to find out what they 8 were doing and what kind of analyses that they had to 9 support what-they were doing, so we would have a better 10 understanding and also at the same time would use it as a 11 flag to say there is a problem. But we felt we needed more 12 information.
13' DR. REMICK: So you are going to mandate some 14 response on what analyses they have done?
15 MR. HODGES: There may well be in a follow-up to 16 the 50.54(f) orders yet to be issued. I don't know.
17 But this one, we want to try to better understand 18 what bases they used for the procedures they did have, what 19 kind of considerations they had put into instrumentation, 20 the availability of other systems, communications between 21 control rooms and other plant staff -- the whole host of 22 questions that relate to this -- and we thought that 23 information was important to get to be able to understand 24 whether or not they were doing this operation safely.
25 MR. EBERSOLE: I just wanted to say that I am not ace. FEDERAL REPORTERS, INC.
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I 1930 08 08 101 llhVbur 1 aware of the fact that it is the standard requirement to 2 provide modulation capability, as Hal suggested you always 3 have in these systems. They are constant speed motors.
4 They may not have valves that stop anywhere near midstream 5 or are controllable at all or even have flow meters.
6 MR. LYON: The Diablo plant has both flow meters 7 and valves that will at least give you a limited degree of 8 control, but they are not control valves per se.
9 MR. EBERSOLE: I am not sure that is a universal 10 capability of PWRs or, for that matter, boilers.
11 MR. LYON: That is one of the reasons for the f 12 50.54(f), is to find out this kind of thing.
13 MR. EBERSOLE: While we are in this mode, any 14 more questions?
15 MR. MICHELSON: You are including all PWRs, I 16 believe, in your letter?
17 MR. HODGES: That is correct.
18 MR. MICHELSON: That means B&W plants?
19 MR. HODGES: B&W plants got the information 20 notice.
21 MR. MICHELSON: Have you thous ' t about the unique 22 characteristics that they introduce, including the loop seal 23 on the pressurizer and the question now about where the 24 water is in the pressurizer as well as the rest of these 25 loops because that comes off generally the very bottom of ACE FEDERAL REPORTERS, INC.
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1930 08 08 102 lkVbur 1 the line, so it is in the fluid system that you are trying 2 to monitor?
3 MR. HODGES: Our initial reaction is that it 4 probably wasn't the same degree of probability in the B&W 5 plants.
6 MR. MICHELSON: You may even have a greater 7 degree, depending upon how careful you are with the 8 depressurizer.
9 MR. EBERSOLE: Further questions?
10 DR. KERR: Are there further questions?
11 (No response.)
12 DR. KERR: I think the invitation should be taken m
13 literally. Stick around for our discussion if you want. We 14 don't necessarily request that you do that. And we do have 15 15 minutes scheduled for some consideration of what we 16 should do.
17 Jesse, do you have a recommendation?
18 MR. EBERSOLE: I would like for the Staff just to 19 sit here and listen because I would like to have them know 20 what we decide to do.
21 We get to a point here where we say, well, what 22 is our part of this? Do we see anything in here that 23 justifies a letter to the Commissioners or to you, or 24 whatever?
25 I take some satisfaction in just this interaction ACE FEDERAL REPORTERS, INC.
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s-1930 08 08 103 lhVburL 1 between ACRS and the Staff, and I think some input from us -
2 - from us to you as it does from you to us has something 3 _ accomplished without all the damn correspondence and an-4 . understanding of what is going on-in the field and what you 5 are doing about it and at least some degree of satisfaction
~
6 as to whether what you are doing is adequate.
7 I don't'know,.I would have to appoint the 8 committee members who by and large are rather -- or there is 9 a quite wide range of interest in these highly detailed 10_ matters, extending _from zero to ferocious.
11 (Laughter.)
12 MR. EBERSOLE: Yet I must ask the committee at
() 13 large for their inputs as to what they think we should do 14 beyond this with due regard to Hal Lewis' long term 15 evaluation of these events.
16 So I just want to open up the table, Bill, or 17 even offer the table to you to ask what do you get out of 18 this and what do you do with this?
19 DR. KERR Do you have recommendations? You have 20 looked at this in detail.
21 MR. EBERSOLE: I guess, I don't know, with some 22 reservations, I am satisfied with Staff's efforts to pursue 4
i 23 this, with one qualifier. I don't have anything that comes 24 through my field here that says, yes, you are pursuing these I) 25 things and I can progressively keep up with it. It sort of Ace FEDERAL REPORTERS, INC.
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llkVbur 1 diffusca into some nebulous state as to what is going on out 2 there, and I lose track as to hew, for instance, you are 3 going to pursue this.
4 I don't have a paper stream. Whether I should 5 have it or not. I have too much paper already.
6 MR. ROSSI: You know we do a lot of different 7 things on events. One of the biggest things I think we do 8 is to try to make all segments of the NRC aware of the 9 events that have occurred that are of significance. So we 10 make the Research people, AEOD, and regions all familiar 11 with the kind of events that are taking place so they can 12 factor that into their ongoing programs.
m 13 And of course we have the information notice 14 program where the significant events are brought to the 15 attention of the utilities so that they will have the 16 information themselves about what is happening in other 17 plants.
18 Then we have bulletins and 50.54(f) letters and 19 that kind of thing.
20 In the case of the Diablo Canyon event that you 21 just heard about, we are planning on issuing a 50.54(f) 22 letter, and there will be a fairly formal follow-up of that 23 particular event for some period of time.
24 Most of the other events today, that will not l'
25 occur. That will be factored into ongoing programs. There Acn FnonnM. RevoRrnRS, INC.
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1930 08 08 105 llhVbur 1 may be information notices, but there will not be a level of 2 response like Diablo.
3 But I think it is important that you people knov 4 what sort of significant events are occurring at the plants, 5 so you will have that knowledge, and I would hope that that 6 knowledge is factored into your thinking and decisions on 7 other issues when the Staff comes before you.
8 I think that is a very important function.
9 MR. EBERSOLE: On these issues themselves, it 10 would occur to me that at these bimonthly meetings in 11 Bethesda it might be just as well if we take the selected 12 incidents here of the previous 60 days and have a page or
-. 13 two of condensed statements as to what follow-on actions 14 have in fact taken place to give us some evidence of either 15 closure or continuity in a very summary form.
16 I don't think that would be much extra paper, but 17 it would give us some degree of continuity or closure on 18 these issues, which I think the committee would be 19 interested in.
20 MR. ROSSI: You know, we can indicate in the i 21 meetings. I would be a little reluctant to agree unless you 22 as a committee feel strongly that we need to do more writing 23 because anything more than we do means additional staff 24 resources.
25 That brings me to another point. I think the Ace FnonnAt. RneonTiins, INC.
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1930 08 08 106 l lhVbur 1 general approach at these meetings is that we will not go 2 back and review the transcript and come back to you to 3 answer all the questions that you may have asked at the 4 meeting. But if you do have questions and you really want 5 an answer, then we will come back to you.
6 DR. KERR: Are you going to provide us with a 7 copy of 50.547 8 MR. ROSSI: Yes. My understanding is we will do 9 that unless there is some problem with it being at some 10 predecisional situation.
11 MR. EBERSOLE: This is really what I am talking 12 about, you know, either the closure or continuity that gets gy' 13 rid of these things as they appear.
14 MR. ROSSI: Certainly, we can tell you in the 15 case of any event what we have done, but we are trying to 16 avoid getting into the too complicated tracking system for 17 these.
18 MR. EBERSOLE: It is just exactly that. What now 19 will take place in the next six months to fix this so it 20 won't happen again?
21 MR. ROSSI: Again, I think on most of the events 22 today that there's probably going to be very little done 23 specifically on these events. The Diablo Canyon one is 24 different. There is a long term concern there. I think you o
- 25 will be aware of what is going on on that one.
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1930 08 08 107 hbur 1 DR. KERR: Mr. Reed.,
2 MR. REED: Jesse, I am satisfied that the oral 3 exchange will affect implementation and follow-up 4 appropriately.
5 At the last meeting something came up on the 6 Peach Bottom sleeping situation. I asked specifically a 7 question, and I got that input via the telephone. I was )
8 very satisfied with that kind of thing.
9 On this particular one, I am concerned about some 10 design details on this Diablo Canyon shutdown cooling. I 11 just passed a piece of paper to the gentleman here. I am 12 sure he will follow it up.
13 I am satisfied with the oral exchange.
14 MR. EBERSOLE: Any others?
15 DR. REMICK: I certainly agree. We are not 16 managers of the Staff, and I don't think they should have to 17 send us follow-up. If we have questions, we should ask.
18 That leads me into why I asked about the 50.54(f) 19 letter. I don't differ with you. I hope it is not a case 20 where the Staff says, gee, whiz, we never thought of this, 21 therefore we need more information for our own edification, 22 and that is the only reason for a 50.54(f) letter.
23 There is going to be a lot of people out there
- 24 spending a lot of time responding to a legal document, and l (_ ' 25 that leads me into the first presentation, which I thought ACE-Fnonnat REi>oniens, INC.
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I s,3 bur 1 was interesting, on management control of plant activities.
u 2 I am not defending the management in those cases 3 for doing an inappropriate job, but we must remember that 4 maybe those managers were explaining to their operators why 5 they can't have radios in the control room and why they x.
-r, 6 might have to have degrees, and ' they might be responding to 7 the current regional SWAT team that is in that week.
8, ,
And so sometimes those managers are tied down c' 9 with all kinds of other things and can't spend all the time
,-A, +
10 that they should be.
a
'll . So I am not' defending them for inattention. I am
-7 12 < 'just saying we have to keep these things in mind when we are 13 asking everybody for information and adding on these 14 requirements.
15 ,
MR. EBERSOLE: Hal, I would like to ask you in 16 particular, because you have an interfacing. activity with
- ,17 this, what your observations are. Are there any 18 observations connected with follow-ups or whatever?
- - .n ,
'r DR. LEWIS:
~
19 No, not really, even though I have a 20 longstanding distrust of all these water level indicators, 21 which is one of the early reasons I was interested in this 22 event.
23 But other than that, I think we are now alerted.
e' - 24' I. hope they don't take too narrow a view of the defects in i 25 the water level indicators and just focus on this particular Acn FEDERAL REPORTERS, INC.
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1930 08 08 109 lhVbur l' bias and this particular issue of what went wrong.
O> 2 This kind of thing is going to happen every time 3
s 3 one of these things is called upon outside of its normal 4 domain of operation, and I am delighted that the operators 5 don't trust the instrument because they are a bunch of 6 crappy instruments from the beginning.
, ,lv;
, 7 MR. EBERSOLE: .I think we all know that we have
- s. 8 had to live with ambiguous water level indicators ever since 9 they started building pumping engines and that they are all 10 subject to error, gross errors. One has to learn how to 1 , .-
11 read them judiciously.
y 12 DR. KERR: Just out of curiosity, what does the A
k-) 13 Staff consider to be the general significance of the
'14 incidence reported at Oconee?
15 MR. ROSSI: The heat exchanger one? I think we
) 16 consider that one to be a fairly significant event. We did bb 17 go back and look ct all --
18 DR. KERR: I am asking -- since it was reported, 19 I assume it is significant -- what is the general e
20 significance of the event?
21 MR. ROSSI: The general significance of the 22 Oconee one, I think, is that they have to be attentive to 23 mechanisms that can ciegrade heat exchangers in plants to the 24 point where if they have an event where they need them they O
(_/ 25 would be degradad to the point where they couldn't perform s
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L 1930 08 08 110 llhVbur 1 their full safety function.
2 MR. EBERSOLE: You didn't mention rate of 3 degradation.
4 DR. KERR: It seems to me we have encountered 5 this frequently in the past. It is something one has to be 6 conscious of. Surely, they must have been conscious of it 7 because they were doing not only calculations for tests to 8 determine this.
9 Are they doing something wrong, in your view?
10 VOICE: What it amounted to, that up until that-11 point in time they had been doing flow testing. The flow 12 really wasn't degraded. You couldn't tell this type of
(%
(, l 13 degradation on the heat exchanger due to the flows it had to 14 do.
15 MR. ROSSI: I think Carl Berlinger may have some 16 additional things to say on that.
17 MR. BERLINGER: The issue with regard to 18 monitoring of the heat exchangers and the heat exchanger 19 effectiveness was an issue which we followed up to determine 20 what the industry was doing, whether the problem that was 21 experienced at Oconee was also being experienced elsewhere.
22 It turns out that INPO had implemented a program, 23 I think in 1984, in which they made several recommendations.
24 One of the recommendations involved a change in the design
~. m l s '25 associated with measurement of flow plus temperatures in
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1930 08 08 111 llhVbur 1 order to do a heat balance, getting away front just 2 monitoring of flow rates.
3 In fact, they have been pursuing this at the 4 individual licensee sites, sending down evaluators, who have 5 already confirmed that the design modifications have been 6 implemented at between 85 and 90 percent of the plant sites.
7 MR. EBERSOLE: What is bothersome to me about 8 this is always looking at the gradual detriment to the heat 9 transfer capabilities. I don't find that there is attention 10 given to the potential for sudden plugging of the thing or, 11 for th'at-matter, release of biologicals, clams. The 12 situation is you don't have any_ time to cope with it.
(.
(/ 13 I recall a suction uptake design one time that 14 was cheap steel piling, which retained a great wall of mud 15 on which there was a dry wall. What held up the cheap steel 16 piling was a bunch of reinforcing rods that led off to 17 deadmen.
18 DR. KERR: Jesse, what are you suggesting?
19 MR. EBERSOLE: I am saying the suggestion should 20 be focused not on the slow degradation process, which can 21 always be fixed, but on the potential for abrupt loss of the 22 heat sink because of sedimentation, plugging, or releasing 23 of biologics.
24 MR. BERLINGER: I believe Generic Issue'51 25 addresses part of the concern, but not the aspect of the ACE FEDERAL REPORTERS, INC.
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1930 08 08 112 (jIbur 1 concern associated with a large amount of silt or sludge 2 being released and suddenly plugging the heat exchanger. I 3 really don't believe that is addressed.
4 MR. EBERSOLE: Imagine the extreme precipitation 5 after bearing on the walls of that reservoir during the 6 winter. I think you will find a pretty clear case of you 7 will just have mud in the uptake instead of water.
8 MR. MICHELSON: Has the generic issue been 9 resolved that you referred to?
10 MR. BERLINGER: Generic Issue 51 is scheduled for 11 resolution -- actually publication of a final report I 12 believe within six mont.hs.
(> 13 MR. MICHELSON: That is the one we ought to 14 treat. It should be expanded to include sedimentation as 15 well as bio-fouling.
16 MR. BERLINGER: It does address silting and bio-17 fouling. -
18 MR. MICHELSON: That is the time for us to look 19 at it.
20 DR. KERR: Other questions or comments?
21 (No response.)
22 DR. KERR: Let's take about a two-minute stretch 23 break while we change shifts.
24 MR. EBERSOLE : I want to thank all of you for
. k_ ) 25 having participated.
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1930'08 08 113 llhVbur 1 (Brief recess.)-
2 DR. .KERR: The next item on the agenda is 3 entitled' " Renewal of Nuclear Power ~ Plant Licenses."
- 4 Mr. Wylie is the cognizant ACRS staff member. Do 5 you have any preliminary comments?
6 MR. WYLIE: Nothing to say other than that at our 7 March meeting Dr. Sheron introduced.the subject. At such 8 time he advised us of the activities that were going on in 9 . regard to relicensing, and I suggested that he update us at 10 a' future time.
11 Also, later in the subcommittee meeting we were 12- scheduled to undertake the subject.
f~
Ts -)/ 13 I think other than that we should just go ahead.
14 DR. KERR: Okay.
.15 Mr. Sheron, the floor is yours.
16 MR. SHERON: Thank you.- I am Brian Sheron, from 17 the Office of Research.
18 We are scheduled right now to spend about an hour 19 briefing you on what we are doing in the area of license 20 renewal policy development.
21 (Slide.)
22 I was originally scheduled to give the briefing.
23 I have asked Don Cleary, who is our project manager for 24 developing the license renewal policy, to give the 25 presentation. He is the principal investigator. As you ACE-FEDERAL REPORTERS, INC.
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1 .might say, he is the person responsible for the day-to-day
'2 management of the activities.
' ~
3 Before he begins, I will just give a little r -4 introduction to remind you. ,
5 I think we briefed the committee in March on'what 6 we were doing in the way of activities. That was primarily 7 a schedule that we gave.you at that time.
8 ~What.we will tell you today is, I think,-a.little ,
i 9 bit-more meat on.the bones, you might say, but there is 10- nothing' specific.. We are trying to firm up our planning.in 11 .this. area.
12 We will tell you'in detail what.we propose'to do. .
13 We will'tell you what the industry is doing, and we-wil1 14 give you an example of some of the policy issues that we see 15- arising from the license renewal policy.
4 16 Just to bring you up to speed,-we briefed Mr.
17- Stello on our activities in early May. The industry had 18 requested and was granted an opportunity to brief Mr. Stello 19 and other senior NRC management in late May on their ,.
20 programs.
21 The briefing that you will be hearing today'is.
22 pretty much what we told Mr. Stello at the time.
.23 We are now in the process -- I think we told you 24 in March -- of preparing a Commission paper, telling the 25 Commission what our programs and plans are in this area.
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llhVbur l_ ~The essence of the Commission paper is also what you will be 2- hearing today.
3 We have here representatives from Research's 4 Division of Engineering, which is responsible for conducting.
5 the aging program, the nuclear power plant aging program.
6 We have representatives from the Mitre Corporation, who are 7 contractors in the policy goal area, and also from the 8 Office of General Counsel, which is providing legal 9 assistance to us.
10 So with that introduction, unless there are any.
11 questions, I would propose to let Don --
12 DR. REMICK: General question. I assume we are 73
(-) 13 talking about renewal of licenses for nuclear power plants 14 and not power reactors?
15 MR. SHERON: Correct, strictly commercial power 16 reactors.
17 MR. CLEARY: I am Don Cleary, the Project Manager 18 for License Renewal, as Brian said.
19 (Slide.)
20 Also, he gave some indication of what we will be 21 covering this morning. We want to cover the need to develop 22 a license renewal policy, the activities that the Staff is 23 undertaking and the Staff plans and our schedules.
24 I want to touch briefly on industry activities, s.) 25 then briefly on some examples of policy and technical issues ACE-FEDERAL REPORTERS, INC.
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A1 1930 08 08 116 j lhVbur 1 that.we have identified so far.
, 2- -(Slide.)
3 A couple of definitions. License renewal is the 4 issuance of a new license.to operate beyond the 40-year term 5 of an existing license.
6 License extension, the term that in the past has 7 been sometimes used interchangeably with license renewal, we 8 are defining as extending the termination date of an 9 operating license to allow 40 years, starting with the 10 initial-date of operation.
11 Then life. extension, or plant life extension, or 12 PLEX, involves not only the regulatory aspects of life-p A_) 13 extension, license renewal, but also significantly the 14 economic aspects from the industry perspective.
15 (Slide.)
16 DR. MOELLER: I am sorryi I don't see the license 17 renewal versus license extension. The renewal you-say is 18 the issuance of a new license to operate beyond the 40-year 19 term and a license extension is extending the termination 20 date of the license?
- 21 MR. CLEARY: The license extension term refers
-22 primarily to those plants, the older plants where the 23 license was started at the time of the CP. The extension is 24 just to bring it up to the beginning of operation.
25 MR. WARD: It is a redefinition, sort of.
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1930 08 08 117 lhVbur 1 MR. CLEARY: Yes.
2 DR. MOELLER: Thank you.
3 MR. CLEARY: This is an overview of the major 4 steps we see in the program and the schedule.
5 As Brian said, wa plan to send an information-6 paper to the Commission. That is almost ready to go. In 7 that information paper the topics that are covered are 8 basically what you are hearing this morning.
9 We are in the process of identifying regulatory 10 policy issues, and hopefully we will have_a draft paper from-11 our contractor about July. It will be a major milestone in 12 the fall, probably in the October-November timeframe, where
(~~
(_) 13 . we will have a report identifying policy options for 14 relicensing, and we will meet with the Commission on this, 15 send this to the Commission, and our intent is to get 16 approval to send this out for-public comment, and hopefully 17 that will go out for public comment in the late fall, early 18 winter at the latest.
19 Then we will be going through a period of time, 20 October through August of '88, where we will be evaluating 21 the comments that we receive from the public and interested 22 parties on the policy options paper that we have published 23 and also pursuing in-house analytical activities to better 24 define and hone the options.
25 This will lead to development of a proposed ACE FEDERAL REPORTERS, INC.
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1930 08 08 118 lhVbur 1 license renewal policy, which we have targeted for September 2 of '88, and we will again go to the Commission and hopefully 3 issue this for public comment and then once again go through 4 a period of revising and honing the policy statement, 5 leading to publication of the statement in September of '89.
6 During this period, we will be moving also into 7 developing draf t regulations, and in September of '89 we 8 hope to have draft regulations available for Commission 9 review and to publish for public comment.
10 Our target is to publish final regulations by 11 '92, and backing up a bit as this process is going along, we 12 will be coordinating with the Division of Engineering and 13 Research, and the Staff will be working on licensing 14 guidelines for industry, which we anticipate should be able 15 to be completed by '95.
16 MR. WYLIE: Before you leave that now, I presume f 17 then that the ACRS would be asked to comment on the options 18 going out for public comment sometime prior to the 19 Commission meeting?
20 MR. CLEARY: That is our understanding. There 21 has already been a tentative discussion about making a 22 presentation to ACRS in the August-September timeframe, and 23 I would anticipate that we would periodically come back to 24 you at key points to brief you on developments in our
~s 25 thinking.
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1930 08 08 119 llhVbur 1 DR. REMICK: Question. I don't know if you are 2 far enough along in your policy development, but I assume 3 there would be some kind of a hearing that would be required 4 for a license renewal. l 5 Has thought been given as to whether that is 6 mandatory or whether it is an opportunity for a hearing, or 7 are you not that far along?
8 MR. CLEARY: For a license renewal for individual 9 plants?
10 DR. REMICK: Yes.
11 MR. CLEARY: I will be touching on that later on, 12 but, yes, that is an important question.
s 13 (Slide.)
14 Just an overview of the prospects ahead of us in 15 the next 15 or so years.
16 We have heard from industry that there are many 17 utilities that would want assurance, reasonable assurance of 18 their ability to obtain license renewal at least 10 years 19 prior to expiration of the original license. Also, 20 utilities would like flexibility in terms of when they come 21 in, whether they need the license 10 years before or a year 22 before.
23 This graph just shows the potential if we assume 24 that utilities will come in 12 years prior to expiration.
'- 25 It demonstrates what we can expect in terms of applications.
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1930 08 08 120 hbur. 1 ~ The bars are just the number of plants, the number of 2- licenses that will be expi_ing 12 years from the date at 3 which they-are positioned.
4 So we have the first one as Yankee Rowe. That is
.5 -indicated in '88. In '90 is Big Rock Point. Then the 6 larger plants start in '95 with San Onofre - 1, Haddam Neck, 7 and-Lacrosse. Then you see a buildup.
8 .So we could be anticipating license applications 9 starting in the early to mid-90s..
10 11 12 13 14 15 16 17 18 19 20 21 22 .
1 23 l
24 O
V 25 I 1
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1930 10 10 121 llkVbw 1 The line indicates you have the flexibility for 2 license applications to come in anywhere between 12 years 3 and 1 year prior to the expiration of the license.
4 What the potential number of application is for any one 5 year.
6 (Slide.)
7 This is a diagram to depict the relationship of 8 various actors in the license renewal policy development.
9 The main responsibility is in research in the Division of 10 Reactor Plant Systems. Here we have Contractual Assistance, 11 Technical Assistance, Mitre Corporation is already assisting 12 us, and we anticipate that they will likely be involved in J 13 providing assistance over the course of this program.
14 ACRS, we see a role for that we will make 15 periodic briefings, keep you abreast of developments and 16 receive whatever feedback you give us.
17 We will be working very closely with the Division i 18 of Engineering in Research. The Division of Engineering has 19 the aging research programs. They are the ones that will be 20 identifying the technical issues, resolving the technical 21 issues that will lead to the implementation of license 22 renewal regulations. Research is working, is setting up 23 relationships with industry now.
24 The Steering Committee, NUPLEX, Nuclear Utilities 25 Plant Life Extension Steering Committee, they will be ACE FEDERAL REPORTERS, INC.
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1930 10 10 122 llhVbw 1 meeting in the next week or two to establish a protocol for 2 interaction of the Technical Subcommittee of NUPLEX and NRC 3 in the area of aging research and related research.
4 OGC. We have been working closely with OGC. We 5 are in the process of preparing a list of issues that we 6 believe are primarily legal or quasi legal, which we will 7 send to OGC in memo form, and they will provide guidance on 8 these issues.
9 Industry and public. This is an important point.
10 We have established, are in the process of establishing a 11 process that is completely open to the public that gives the 12 public an opportunity to comment on our work as it u' 13 progresses. As I indicated in the major milestones before, 14 there are a number of points where we will be requesting 15 public conmment . All of the meetings that we have relative 16 to this program, memos will be written and put in the public 17 reading room. All the correspondence and reports will be 18 placed in the public reading room.
19 DR. OKRENT: What do you mean by "the public"?
20 Are you implying that some large representative portion of 21 U.S. citizenry will know about what you are doing?
22 MR. CLEARY: No, the public is a general term.
23 It likely will be -- it includes industry and interested 24 activist groups, citizens interest groups, as well as any
- 25 individual members of the public who care to follow the ACE FEDERAL REPORTERS, INC.
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_ 11930 10 10 123 l hVb'w 1- developments.
2 DR.'REMICK: Another question. Has OGC come to
'T 3 any determination whether license renewal triggers NEPA? Is 4 'this a major federal action?
5: MR. CLEARY: That is one of the questions that we-6 have asked them. Perhaps we have an answer.
7 VOICE: In'short, no. . We have not discussed the 8- issue.
. 9 DR. REMICK: I didn't think this was going to be-10 OGC's answer. ,
11 MR. REED: I think this is going to be a very 12 interesting issue. There will be a clash of forces 12
} 13 years out, let's say. The first plant, Yankee Rowe, if we 14 are all in brownouts and backouts, perhaps it will get 15 through the process, as it goes out for hearings. But if we.
16 are not in blackouts and brownouts, then it will unlikely 17 get through the process, because beyond aging and all these 18 .other things you have the aging of regulation. You go back 19 to Yankee Rowe, and it was built without -- they had never 20 heard of OA and QC. They had never heard of these thing, 21 you know. You used craftsmanship in those days rather than 22 paper.
23 So the whole notion that you are going to lay on 24 the table, the kind of thing that can go through a hearing, f)'i s . 25 is crazy.
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1930 10 10 124 llhVbw 1 DR. SHEWMON: Well, if we jump three or four 2 slides, we will get to the interesting questions. He has 3 some of those on .
4 MR. CLEARY: One other organization, TIRGALEX, 5 was established by the EDO. TIRGALEX stands for Technical 6 Integration Review Group for Aging and Life Extension. That 7 group, that is a group of senior managers within NRC.
8 TIRGALEX has produced a report, which has been reviewed and 9 revised within Research, and I understand from Bob that a 10 new group, coordinating group, will be established to 11 oversee the integration of aging and life extension, license 12 renewal activities across NRC.
l
- 13 (Slide.)
14 Resource Requirements. This is a program that 15 has and will continue to have close management attention 16 from senior management. Brian Sheron, the Director of the 17 Division of Reactor Plant Systems, has a very strong 18 presence in this program, and the chief and section leaders 19 of the Reactor Plant and Safety Issues Branch, are very 20 involved. There is one full-time Staff member on that.
21 That is myself, as the task manager. We anticipate 22 considerable demands for review assistance from Technical 23 Staff outside in other divisions and other offices. We have 24 Tom Dorian, Senior Staff Attorney, who has been assigned to
.; 25 oversee and monitor this from the legal side, and I ACE. FEDERAL REPORTERS, INC.
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1930 10 10 125 llhVbw 1 understand that he, on occasion, will draw upon other 2 attorneys in OGC for legal research and analysis.
3 The Technical Assistance. As I say, we have the 4 Mitre Corporation on board. They started work in early 5 April, and we anticipate that they will be providing 6 assistance to us through the course of the program.
7 I mentioned that the Aging Research program, the 8 close coordination that is required, that is a very large 9 program, in terms of dollars, and hopefully, our interaction 10 will help to focus some of the research on issues, so that 11 we will be in the position to have workable, meaningful 12 regulations in the early '90s.
_ 13 Also, Brian Sheron has requested a senior 14 individual from NRR as a point of contact, because we see 15 the need for meaningful and occasionally intensive 16 interaction with that office.
17 DR. KERR: You mentioned you hope that you have 18 menaingful regulations in effect as a result of the Aging 19 Research.
20 Have you got anything specific in mind? What 21 sort of new regulations would be likely?
22 MR. CLEARY: What I meant to say was that the 23 technical basis for regulations will be, to a great ext ent, .
24 dependent on the reseach that is conducted between now and
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1930 10 10 126 llkVbw 1 will hopefully result in research questions being answered.
2 DR. KERR: This new set of regulations for plants 3 that are being relicensed as opposed to plants that are in 4 initial license? I am trying to understand what these 5 regulations are.
6 MR. CLEARY: The regulations I referred to are 7 the ones that we intend to propose and publish in 1992.
o These would be 10 CFR regulations.
9 MR. SHERON: Dr. Kerr, let me try and elaborate a 10 little bit. It bears on Glenn's question a little bit too 11 about older plants that weren't designed to modern 12 construction codes, the ASME code, et cetera.
13 If you asked the industry today, if they had to 14 relicense a nuclear plant using the regulations that existed 15 or were in existence at the time that they applied for 16 relicensing, most of them would tell you that they would not 17 relicense a plant, because they could not meet the current 18 regulations, not from the standpoint of implying that the 19 plant is unsafe. It is just that, for example, the plant 20 was perhaps designed to a version of the ASME code, that at 21 the time they applied for relicense was perhaps 50 years 22 old, and that the new version of the code would have 23 requirements that obviously could not go back and be met by i
24 that plant.
- 25 We are approaching the situation that a) in order ACE-FEDERAL REPORTERS, INC.
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1930 10 10 127 lkVbw 1 for a plant that wants to operate beyond 40 years, it would 2 have to have a new regulation that would apply to only 3 plants that have operated for 40 years. I think we are 4 trying to approach it from the top down. That is to start 5 by saying, what is the mandate of the Commission, and that 6 is to protect the health and safety of the public from the 7 commercial operation of nuclear power plants.
8 The next thing we are trying to do is say, given 9 the plant has operated for 40 years, we have the operating 10 experience, the operating history, data base, et cetera, et 11 cetera.
12 What regulatory framework makes sense for that 13 plant, to ensure that it can be operated safely during the 14 next, whatever, 10 to 20 years. That regulatory framework 15 does not have to be the existing one. It can be a different 16 one. We are exploring what options are available for that 17 framework, the extent to which they be performance-based 18 regulations, the extent to which we should invoke PRAs, 19 safety goals, backfit policy, and the like. All of the come 20 into play, which Don will discuss in a little bit when he 21 discusses the policy areas. And this is kind of the maze we 22 are trying to untangle or find our way through, I should 23 say.
24 DR. KERR: Let me hypothesize something. Let's I
25 suppose that you were trying to achieve about the same level ACE FEDERAL REPORTERS, INC.
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1930.10 105 128 llhVbw 1 Lof safety with the relicensed plant which you are with the
- 2. current plants.- It seems to me that those existing 3 . regulations to determine safety either ought to fit, or if~
4 they. don't fit, they must~have things in them that don't 5 have much to do with safety. You need the existin~g
- 6. regulations to determine safety. If you are going to operate 7 at the same level'of safety, it would seem that either of 8 the existing regulations should work, or else there is a 9 -bunch of stuff'in existing regulations that doesn't have 10 much to do with safety.
11 DR. SHEWMON: What are you going to'do with
-12 physical separation, which is'different now than it was 20
)' 13 -years' ago?
g 14 DR. KERR: I am-just-saying, if the physical 15 separation is necessarily the same thing, and you.can't get
16 it with these plants, then there has to be some alternative,
< 17 inlwhich case it case it seems to melyou modify the existing-18 regulations to allow either' physical separation or whatever 19 the alternative is. If you don't do that, it seems to me 20' that you cna't be sure that you are going to have a very 21 good indication that you are getting the same level of
' 2:2 safety.
23 I want to be educated now. Maybe I am missing 24 something here.
( 25 MR. SHERON: What we are looking at, for example, ACE FEDERAL REPORTERS, INC.
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1930-10 10 129 l hV'bw 1 I think what you are describing is very similar to the SEP 2 program, where one takes an. older plant, usually against the
'3 current regulation and makes a list or puts in all the areas 4 where that plant doesn't meet current regulations. Then you 5 have to examine each one of those areas individually, as an 6 aggregate and decide, should I do something? Is there 7 something about that plant that doesn't meet these 8 regulations that makes it unsafe, so that we should fix it.
9 This is one option we are pursuing, as one way to go about 10 looking_at these older plants.
11 To do an SEP type of review, to consider all the 12 areas where they don't meet the current regulations and make m
k_) 13 a' decision based on PRA risks or whatever and whether we 14 need to fix that plant in certain areas. Keep in mind also 15 that the regulations have changed -- with the exception of 16 some, have changed very little. What has changed, is the 17 Staff's interpretation, I believe, of some of those 18 regulations.
19 DR. KERR: That reminds me of the way I give 20 final exams. I give the same exam every year, but I change 21 the answers.
22 (Laughter.)
23 MR. SHERON: That is true. The way one 24 implements the regulation in reality is the Reg Guides 25 through the standard review plans and Staff technical Ace FEDERAL REPORTERS, INC.
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1930110 10 130 llhVbw 1 positions. These are the things that have evolved and 2 changed over the years.
3 DR. KERR: Possibly one would use the same 4 regulations but would change the reg guides, let's say.
5 MR. SHERON: The general design criteria have 6 remained essentially unchanged since 1971, but for the.most 7 part, the GDC would govern.
8 DR. KERR: So_you wouldn't, as a result of the 9 aging research, anticipate any major changes in regulations.
10 MR. SHERON: -We have asked -- before we 11 reorganized, I prepared a user need letter to the Of fice of 12 Research. I guess maybe I was telling myself, rather _ than p)
\_ 13 my colleagues, what we would be looking for. But what we
. 14 said is, that as they go through the aging program, the end 15 result of that research on aging should not be a list of 16 NUREGS, which says, here's what aging is all about, or 17 here's the way aging affects components, but to carry that a 18 step further and say, what does this mean from a safety 19 standpoint? What should we, as a regulatory agency, do as a 20 result of what we have learned from this research? Is the 21 information we have learned on cable degradation telling us 22- that we need to use a letter to the industry tellin them to 23 fix something?
24 Do we need a new regulation that says every five
( 25 years you have to examine your cables?
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'1930-10 10 131 llhVbw 1 This is one: thing we would like to get'out of-the 2 aging program is what regulatory actions does this agency 3 have to take?
4 DR. KERR: So in a sense, these regulation 5 changes, if they are required, might apply to existing 6 plants, as well as relicensing plants. If, for example, you 7 need to do something every'five years --
8 MR. SHERON: I look at license renewal, the aging 9 aspects that apply.to license renewal are a subset of the 10 aging research program itself. Aging applies to a plant 11 whether it is ten years or fif ty years old.
12 DR. KERR: Thank you.
.'wp) 13 DR. SHEWMON: We talked about maintenance of the 14 existing levels of safety.
15 Is that for the plant?
16 MR. SHERON: I am sorry.
17 DR. SHEWMON: I sort of wish we would get on past 18 these organizational details.
19 MR. SHERON: Why don't we d'o that, and then we
! 20 can deal with the question, maybe.
21 DR. SHEWMON: If we can go faster than we are 22 going now, we will get there.
23 VOICE: Let me add just one point to the 24 explanation that Brian made.
l 25
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2 There are two aspects. One is a sustantive 3 aspect that Brian just_ discussed. The other is the process 4 for . the regulations. You have to make sure that the new 5 licensing-process is clear and explains _what the substantive 1 6' points are, and we have to make sure that the_ process that 7 is due -- the due process to licensees and the public, is 8 made clear and is enforceable.
9 MR. CLEARY: I will shift over the next several 10 slides.and pick up. I think it would be appropriate to-11' summarize J the industry's position that they gave to us.
12 DR. OKRENT: Excuse me. Would you put on the one 13 before the industry position?
14 MR. CLEARY:. The schedule?
15 DR. OKRENT: Themes.
16 MR. CLEARY: That is the one I was going to-start
! 17 with.
18 (Slide.)
19 There are two basic themes that came out of 20 industry's efforts at looking at license renewal policy and 21 what they knew about plant aging and life extension.
22 One is the continuity theme. The other is the 23 extant licensing basis. The continuity theme is that there 24 is very little difference beyond 40 years and prior to 40 25 Ace-FEDERAL REPORTERS, INC.
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t-21930.11 11 133 llhVbw- 1 : years,~and that the programs that industry has for 2 . maintaining safety of the plant, maintaining its economic -
3 quality and meeting NRC regulation requirements, that this-4 .would go on after 40 years, I suppose prior to 40 years, and i
5 that this should be a major theme in any regulation that NRC 6 develops.
7 The extant licensing basis is basically that-8 these plants were licensed to meet certain standards and
~
.9 conditions and that these standards and conditions have been 10 as modified in individual licenses, adequated, and if they 11 are adequate now, that the licensing basis ~should continue 12 to'be-adequate in the future.
3
~(V 13- DR. OKRENT: Don't take it away, please.
14 I guess I could understand this as an approach 15 that industry would propose, but I.would suspect that if you 16' went to other groups within the country, you might get.other 17 answers to the question of continuity- and extant licensing 18 and so--forth from a philosophic point of view.
19 I would suggest you might do well to explore 20 those somewhat early rather than at the time of putting out ,
21 a draft NEPA, if you are going to have to do that. But to
~
22 -get more specific, my casual observation of aircraft is 23 that, in fact, after a certain time, I sense an increased 1
24 failure rate. New kinds of failures, enough that I, myself,
)~ 25 1
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- 1930 11.11 134 llhVbw 1 become reluctant to rely on very old commercial aircraft,.
2 and I don't think it is purely subjective. I have little 3 reason to think that however good your aging research 4 program.is, it will find everything that is significant.
5 I think if one looks at history, and so' forth, 6 one should anticipate that there will be important surprises 7 .that come up as the years go by. If my surmise is correct, 8 the philosophy on the Board makes no allowance for this, and 9 in fact, even if you do a PRA, which usually looks backward
~
10 for its data, it is difficult to make allowance in this 11 regard.
12 To provide a philosophic theme to the comments I s
13 have just made, it seems to me that one can make arguments 14 that for plants that have gone through one era of licensing 3
15 and are being proposed for some substantive additional 16 period, that one might find it not only prudent but fair to f 17 include such new modifications in safety as one thought 18 could either help to make up for some inevitable 19 deterioration from original quality or to help cover at 20 least 'some considerable class of new things that might 21 ~ occur, which are not covered in the original plant.
22 I see no sign of that, either in this original 23 theme or in anything I have heard yet from the Staff.
( 24 MR. CLEARY: This will be coming up two slides 25 1.
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llhVb'w 1 from.now. Perhaps I'could just flash the next slide up, and 2 . then we will go_on.
3 (Slide.)
4 DR. KERR: How many 40-year-old electric i
Does anybody have any idea?
~
5 generating station operate? Is 6 it a large number of a small number?-
7 MR..WYLIE: I would say it is a large number of- i 8 fossil plants.
9 MR. REED: And an even' larger number of 10 hydroelectric. ,
11 MR..WYLIE: Some of those, 50-60 years old.
12 DR.-KERR: So there is a significant amount of ,
r'g
(_/ - 13 experience now with 40-year-old, nonnuclear plants? ,
14' MR. CLEARY: There is; yes.
15 DR. OKRENT: When you talk about old hydro
- 16 plants, I think you may look back and find that not a small 17 number of them are designed with insuf fic'ient bypass
-18 capability,.for example, compared to what is done today and(
19 in a variety of things like this.
20 DR. SHEWMON: Bypass capability in a hydro plant? ,
21 DR. OKRENT: In other words, there's some flood 22 level,.and they are accommodated to bypass. And if you
'23 would see this, it would be over the top.
24 DR. SHEWMON: Okay.
[
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) 7bw 1 DR. MARK; You are thinking of the one at "2 Niagara.
3 i DR. OKRENT: The very new ones have increased 4 bypass capability.
5 DR. SHEWMON: Did you just put that slide on?
6 ,
MR. CLEARY: I am going to jump along, because 7 ouri discussion in the next couple of slides will, in fact, n
8 embody the points that industry has made.
9 DR. SHEWMON: Fine. I would be interested in the 4 , 10' area of the definition of the maintenance of existing levels 1 !, ,
11 of safety, existing where and when. Averaged over what.
12 group.-
(,4 )O 13~ MR. CLEARY: That is on a plant by plant basis.
14 If a plant is meeting regulatory requirements, industry say,
- s 15 by definition --
4 . 16 DR. SHEWMON: There shouldn't be a ratchet, all 17 of a-sudden, when you turn the calendar over to the 41st 18 year?
19 MR. CLEARY: Yes.
20 (Slide.)
21 ,
This is just some examples of policy issues that-22 we are developing. The first one is, should we look at-
, s L 23 license renewal as a new license versus an amendment? That l
24 is legally, in terms of procehs, whether or not it is 25 i
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[1; legallyfa new license or legally an amendment,;should the ,
, ,'J2. process,.the review process.'look more like that than the -
r .- I -
"3 traditional new licensee CP will review? Or does it look-u:
- 4. more.likeLan amendment process?
T 15- DR. REMICK:' What is the precedent you are 6: setting in that power reactor area? 'You have got a number-7 of those'.
, 8- VOICE: We are looking at'this anew. It is a new 9 question.
10- DR. REMICK:: But' you have extended ~ licenses of a 11 number of nonpower; reactors.
i 12 Have-those been as amendments or as license r
7 .q
- il 4
13 renewals?
14 VOICE: The statute is very broad. We are going d
15 to look at-the statute, and we are going to look at how much
- 16 freedom we have and what the policy constraints are, and we i 17 are going to use existing precedents. It'is not going'to be i
.18 that influential.
19 DR. SHEWMON: Will you answer the question, just
- 20 for the heck of it?
21 VOICE: I don't understand the question beyond 22 that. Precedent is precedent.
23 DR. KERR: He said what have been used for 4
24 nonpower license extension.
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,1930filJ11' 138 lhVbw. l' DR. .REMICK: A number of nonpower reactor 2 licenses have come to the end of their initial- licenses, and 3 they have been extended or renewed, I don't know which.
~4~ VOICE:. I think we have amended them.
5 DR. REMICK: That is what.I thought. But you 6 don' t see that?
7 VOICE: ~I do not see that as being influential or 8 very influential on this. I think this is a new question.
-9 DR. REMICK: Why not. Isn't Part 50~ basically.
10 -the same section of the regulations?
11 VOICE: The regulations, yes, butLthe statute is L
12- different.
13 MR. CLEARY: The next item is one of- flexibility 14 in.the timing of renewal. It has been suggested there'are 15~ several issues here. One.is how early can an applicant'come 16 in for renewal and how quickly can the applicant get some 17 indication. some fairly solid indication of license renewal.
, 18 Many utilities that responded to our request for public 19- comments, are talking in the range of ten years.
- . 20. Some utilities would need the flexibility of the 21 decisionmaking process to come in, perhaps as late as a year 22 before the expiration of the license. There is also the 23 issue of what form that renewal takes. Does it become 24 effective at the termination of the original 40-year
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l 1930 11 11 139 llkVbw 1 license? Or is it possible for the license to supersede the 2 40-year license, the utility thereby giving up the 40-year 3 license and moving into the new license at the decision 4 point, some years before the end of the 40-year license?
5 Then there is the issue of the third point. The 6 term of the renewal license. Some utilities would want 7 several years to carry them over, while new capacity that is 8 perhaps under construction but behind schedule, other 9 utilities may want 20 or 30 years or perhaps even 40 years.
10 Then along with that is the question of flexibility.
11 Do we have a set term, or do we leave it up to 12 the utility to request a term?
13 The fourth item is the timely renewal doctrine.
14 How far in advance of the licensing exploration should the 15 utilities submit their application?
16 Environmental review. There is a programmatic 17 environmental impact statement required in the case of each 18 license renewal application. Is an environmental assessment 19 adequate, or will we have to do an environmental impact 20 statement from scratch?
21 Public hearings. What triggers a public hearing?
22 When do they take place, and what should the scope of public 23 hearings be, if they are required?
24 The next point is applicability of existing 25 ACE FEDERAL REPORTERS, INC.
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1930 11 11 140 llhVbw 1 regulatory criteria. Should the relicensing be based on the 2 conditions that the utility is operating on at 40 years 3 minus one day, or do we apply new criteria that reflect the 4 standards, the Staff interpretation at the time the license 5 renewal is issued?
6 Then there is the issue of the backfit rule.
7 Should the license be divorced from the backfit rule, or 8 should it be bound by the backfit rule?
9 The role of the safety goal.
10 The weight given to management performance and 11 what weight should be given to management performance versus 12 the physical condition of the plant.
13 If you have a plant that passes physical muster 14 but there has been poor management performance, how is that 15 taken into consideration in the license renewal?
16 The issue of decommissioning. The timing of 17 decommissioning applications and treatment of funding of 18 decommissioning.
19 The issue of high level waste.
20 DR. SHEWMON: What has decommissioning got to do 21 with whether or not you grant them the new license or renew 22 the old one?
23 MR. CLEARY: There is the issue of 24 decommissioning fund continuing to contribute.
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' ~ 1930511 11- 141 llhVbw1 1 DR. SHEWMON: You meant that is not determined by-2 inflation and projected costs but by some formula? Do you_
3 want to know if you should stay with the formula or try to 4 recalculate it?
5 _MR. CLEARY: Yes. It is probably one of the
_ 6- easier questions and certainly not_one of.the technical 7 questions.
8 DR. MOELLER: Did you cover emergency planning?
9 MR. CLEARY: I did skip that; yes. There is a
, _10 question of what do we do with emergency planning. Do the 11 same emergency planning requirements carry over beyond 40 12 years, or.is there some reason that they need to be changed, f3
_() 13 to be rexamined?
14 Now the high level wastes. Does this become a 15 consideration at any point? Do we have continued confidence 16 in the ability of the nation to dispose of high level waste,.
17 when we reach the mid '90s or the year 200?
18 Price-Anderson. Are there any considerations 19 there?
20 And does an antitrust review have to be done?
21 Technical issues. There is the issue of defining 22 the physical scope of license renewal. What component 23 systems and structures should be we be looking at? Should 24 these be component systems and structures that have been 25 l
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~ 11930.11111 -142 hbw :1 cdeermined to be~ subject-to age-related degradation?- What 2 role does an operational performance and records play? How-3 are-they treated'and how do you treat variance in. quality of 4 operating records?
5 . Original design life. The basic question. of what 6 was the original design life of the plant, and how should 7 the information on the original design life or lack of 8 information~be treated?
9 DR. KERR: If you can continue to the rest of 10 your presentation. We only have about seven more minutes.
11 MR. CLEARY: And the role of probabilistic risk 12 assessment. To what extent.does that.have a role to play?
b 13' Is it-a key role in the relicensing review, or does.it play- '
.a peripheral role?
.15 DR. REMICK: A question on that slide is there 16 any consideration being given to what whether one chould
-17 utilize a programmatic environmental review as part of the 18 .overall rulemaking in lieu of the possibility of individual 19 environmental assessments or environmental statements for 1 20 individual plants? Is any consideration being viven.to that 21 option?
22 MR. CLEARY: That will be considered; yes. If 23 there is a programmatic environmental statement required, 24 then the question is a case by case environmental impact
- p/
,,- 25 4
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1930:11 11 ~ 143 1 assessment, statement or assessment.
llhVbw-2 (Slide.)
3 Here is a . few examples of policy options .that we 4 are starting to look at. The first one is, meet licensing 5 criteria that exist- at the time of the license application.
-6 That would be a thorough review and probably involve a lot 7 of upgrading requirements.
8 The second is, take an integrated safety 9 assessment approach in a review. The third would be a 10 detailed PRA, modified to accommodate time. So it would be 11 a forward looking PRA to assure that the plant meets safety.
12_ goals.
(_) 13 The next is, require enhancement of maintenance 14 surveillance and replacement programs to ensure age-related
.15 degradation is minimized.
16 This could be' a primary focus and, of course,
- 17 could be a component, combined with some other approach.
18 The second to last is, do nothing dif ferently in 19 regulating the plant. That is, just continue to regulate 20 the plant as if the license wasn't 40 years, but was at some 21 point in the future.
22 And the last is, do not renew the license. This l 23 is in here as an option to carry through the analysis, at 24 least to provide a check on other options that we are
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2 (Slide.)
3 This is a high visibility program. It has 4 congressional and GAO attention. GAO has expressed concern 5 over the influence that industry may have on the process.
6 As I indicated before, we are attempting to have a complete 7 open process where everybody has a stay in all options.
8 Anything of significance that is said will be tracked 9 through the program and explicitly handled, carried forward 10 and disposed of in an a recorded matter.
11 MR. MICHELSON: Would you explain briefly, the 12 linkage to Surry? What Congress is thinking about?
13 MR. CLEARY: Brian?
14 MR. SHERON: They believe the single phase 15 erosion of the pipe was a phenomenon that was age-related 16 and occurred over a period of time. And in Mr. Markey's 17 opinion, I guess, it signifies how nuclear plants will 18 deteriorate.
19 DR. MOELLER: When you say GAO has two staf fers 20 attending meetings, what are these meetings?
21 MR. SHERON: They attended -- the industry 22 offered to brief Mitre, our contractor, on their activities.
23 The GAO people attended that meeting. They attended the 24 briefing that the industry gave Mr. Stello. They have come i 25 ACE-FEDERAL REPORTERS, INC.
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1930 11 11 145 llhVbw 1 down and spoke with a number of Staff members. We just 2 spent about two hours with them yesterday. They are 3 overseeing very heavily our research program. Basically, o
4 they are just there all the time.
5 MR. MICHELSON: Is this relative to aging?
6 MR. SHERON: No. Relative to aging and the way 7 aging factors into licensing renewal.
8 (Slide.)
9 MR. CLEARY: In conclusion, the Staff has begun a 10 program which can be expected to result in publication of a 11 policy statement in 1989 and final regulations for license 12 renewal in 1992. The procedures are being developed to 13 assure openness and adequate public participation, 14 paricipation by all interested parties. Efforts are under 15 way to assure coordination within NRC. Resource 16 requirements are being identified now and will involve 17 technical assistance dedicated to technical assistance, 18 technical research and technical staff.
19 Industry activities are being closely monitored, 20 and so far, industries interaction with us has been 21 primarily on relicensing policy rather than the technical 22 basis for relicensing.
23 Hopefully, with the procedures that will be set 24 up in the coming weeks, with the Technical Subcomamittee,
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hbw 1 this will be corrected.
2 DR.-OKRENT: Since at least in considerable part,
.3 aging effects appear to have a strog relationship to. ,
4- relicenseability, at the time this might be approved for, 5 why does not the NRC look to industry to perform the lion's 6 share of everything that is necessary about what can happen 7 via aging?
8 MR. CLEARY: This issue has been raised and 9 discussed. In fact, in industry's briefing of Mr. Stello, 10 he made that point very _ emphatically that he felt that the 11 research programn for life extension should be acclerated 12 and that industry should be taking a greater responsibility
() .
13' for. approving the continuing safety of the component systems 14 and structures.
15 MR. BOSNAK: I would like to add something.
16 Bob.Bosnak, Division of Engineering.
17 We intend to put a greater burden on the industry 18 to solve some of the-problems. Obviously, we don't have all 19 the resources in the world to anser the questions, 20- partricularly those that might involve some of the more 21 expensive components, like the reactor vessel and radiation 22 embrittlement. If there is no answer, obviously, that has 23 to affect the license renewal policy.
24 So we intend to put the thrust on the industry to
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solve some of the problems'that we.have questions on, but we 2 don't.have answers for.
3 DR. OKRENT: 'I would assume there must be a very 4 considerable number of different kinds of cabling and 5 different kinds -of relays, and so forth and so on, that have 6 ~gone-into the plants over the years and.that you cannot.get 7 generic information that is meaningful across-the-board.
.8 MR. BOSNAK; That is correct. And I think the 9 industry. approach to that is that th'ey intend, no. question, 10 .to-just renew those things for which they have no answers on-11 it.
12 DR. KERR: Gentlemen, we.have a.short lunch hour p-
-V 13 scheduled.
~
14 Unless there are further comments, I would like 15 .to than'k the group from the Staff, and'we will go to lunch.
16 We will be,back at 1:00 o' clock.
17 _ (Whereupon, at 12:15 p.m., the meeting was 18 recessed, to reconvene at 1:00 p.m., this same day.)
19
- 20 21
- 22 23
, 24 A
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1930 13 13 148 t'*Nbur 1 AFTERNOON SESSION U
2 (1:00 p.m.)
3 DR. KERR: Gentlemen, we have with us this 4 afternoon Mr. Denton, in his old responsibilities and new 5 responsibilities, to bring us a perspective on strategic 6 planning.
7 Welcome.
8 MR. DENTON: Thank you, Mr. Chairman.
9 It was last year, I believe, that you wrote to 10 the Commission and discussed the need for strategic planning 11 within the agency and listed a number of assumptions that 12 you have arrived at in order to talk about future health.
13 That coincided with Chairman Zech's own views
[}
14 that the agency needed a strategic plan. He has found 15 himself in the condition of having to approve budgets 16 without having an overall view.
17 lie formed a group of senior managers. I was 18 named Chairman of that group, and Jesse Bunches was 19 Executive Secretary for it. It consisted of myself, the 20 Directors of Research, NMSS, Resource Planning and 21 Pe rsonnel, the regional representatives, Inspection and 22 Enforcement.
23 We developed the first draft of a plan, came down 24 and briefed the Commission on that plan, got their comments.
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1930 13 13 149 f"'Nbu r 1 developing the plan.
U 2 We engaged several consultants, who knew a lot 3 about strategic planning. We had one meeting with 4 representatives from industry to see how they did strategic 5 planning.
6 We developed a second major rough draft. We 7 recently went out to Bethesda with all the senior managers, 8 including Ray Fraley, to discuss the contents of the plan.
9 The plan has now been sent forward to the Commission, and 10 they are considering the plan.
11 The budget that is being developed for the next 12 five years is being based largely on the presumption that
/~~T 13 the Commission will concur in the plan. I think the Q-)
14 Commission will consider the plan over the next month or so 15 and hopefully adopt it and then immediately begin the 16 process to revise the plan.
17 The idea is the plan is a living document, and 18 every year it will have to be revisited and assumptions 19 relooked at and new strategies proposed and more analysis 20 done.
21 I have handed out, if you would like to go 22 through it, just a brief synopsis of some of the highlights 23 in the plan. I am using this draft, I think, that Mr.
24 Fraley just passed out.
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-1930'13 13 150 r ^1Nbur 1 responsibilities stop. It was to develop the overall goals G
2 and strategies, but not to try to develop the detailed 3 programs in the budget.
4 The next page points out we developed eight major 5 goals.
6 What we are trying to decide in developing this 7 plan is what road should we be on, what is the right tr ,
8 and we focused on potential changes to today's approaches.
9 We ended up, also, adding some approaches which we thought 10 should not be changed.
i 11 It is the collective judgment of the managers 12 that I have described that we didn't have time to do the 13
{') normal detailed backup of assumptions and alternatives.
14 One major addition to this plan over the first 15 draft, in the research area we have included a description 16 or research philosophy, based largely on our reading of the 17 critique that was done by the Academy.of Science, and we 18 have tried to develop goals and strategies for rescarch that 19 flow from such a philosophy. ~
20 The next pages summarizes some of the 21 assumptions. Many of them are ones that you had 22 recommended, but I will go over the ones that we ended up 23 thinking were the major ones.
24 Obviously, it is the end of an era in licensing
{} 25 new plants. The major challenge confronting the agency will ACE FEDERAL REPORTERS, INC.
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2 We assume we are going to have a relatively 3 unchanged safeguards environment. We think there will 4 continue to be variations in the performance of all of our 5 licensees.
6 We think we need a bigger emphasis on waste 7 management in the agency than we now have. We need to 8 position ourselves for any new applications, so that in the 9 event new . plants are needed by the country we can have in 10 place the process to review those.
11 MR. EBERSOLE: Harold, may I ask a question?
12 The emphasis on waste management. I would like
(~} 13 to ask you whether you regard that emphasis as being driven x>
14 by a technical need for safety or a political-social need to 15 satisfy the political process?
16 MR. DENTON: Well, I couldn't punt like you would 17 when I asked the committee's views.
18 MR. EBERSOLE: I am bothered by taking a 19 technical term in the direction where technology has no 20 a nswe rs .
21 DR. SHEWMON: Or where some of us think it has no 22 answers and others may disagree.
23 MR. DENTON: I think it was the consensus of the 24 senior managers that we weren't giving enough attention to
/"N 25 waste management. In the broad context, it needed more
(_)
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2-1930 113,.13- 152 2/~}Vbur' -1 policy' development, perhaps more technical content.
O 2 Now that the Congress has passed laws, we have 3 got every day reactors generating these wastes and, like it 4 or not, we have got to come up with in this country a 5' suitable low level or high level plan.
6 The Congress adopted these waste compact 7 approaches, and we just see a lot more attention being 8 needed by the agency in making those solutions come.to
/ 9 fruition.
10 It might not be all high tech, but it has got a 11 technical component and.a societal acceptance component. So e
12 if we are going--to have reactors generate waste, we have got-l
{} -13 14 to have NRC programs dedicated to disposing of; waste.
Finally, the increasing involvement of state and 15 local governments is just obvious in many contexts. That is 16 an area that we had not given enough attention to in the 4
- 17 past.. We need to find ways to interact a lot' more closely 18- with state governments.
19 The era of the AEC having sole jurisdiction over 20 nuclear matters seems to get chipped away at and is 21 continuing to move in that way. There is, for example, a 22 revived interest in agreement states among the states 23 because they want to license their own low level burial 24 grounds.
25 So we sat with about 28 agrooment states for i
[ }.
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1930 13 13 153 r""Nbu r 1 many, many years, and suddenly there are a half dozen states
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2 interested in becoming agreement states, mainly driven 3 because they want to license their own low level disposal 4 sites.
5 DR. REMICK: Harold, in the bullet, the second 6 from the end, future licensing activities, has any thought 7 been given to positioning for reprocessing, recognizing that 8 the covenant is fixed in with reactor licensing in Part 50?
9 Has any thought been given to having a position there just 10 in case?
11 MR. DENTON: I don't think we thought about that.
12 This is sort of a five-year plan. The detailed assumptions
{} 13 are in the back of the plan. The plan hasn't been released 14 to the public yet.
15 DR. REMICK: I have often thought when there is 16 no license there to have to react to is a good time to think 17 about pulling it out of Part 50, where it is all 18 intermingled, whether it is power reactor or reprocessing, 19 and put it in a separate part, kind of like Part 72.
20 I realize it is not a high priority item.
21 MR. BUNCHES: Ono of the areas they are looking 22 at is the advanced reactor area. We are doing some work on 23 looking at what type of regulatory framework would need to 24 be in place for reprocessing.
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.V 2 DR. MOELLER: Your assumptions, though, included 3 an item'that we would not be processing, which is spent 4 fuel, didn't they, over so many years?
5 MR. BUNCHES: Right.
6 MR. DENTON: The next page summarizes the major 7 goals. They are somewhat self-evident, but they took us a 8 lot of discussion to decide what our major overall' goals 9 were, and on page 4 they are summarized. I won't spend any 10 real time on them. Each one in the plant has a-lot of 11 strategies underneath it.
12 On page 5, it just sort of summarizes some of the-13 changes that I think the agency would have to achieve in 14 order to move in this direction. It puts an emphasis on 15 being proactive rather than reactive. You may want to 16 question those terms, but we stuck with it.
17 What we mean by that is let's anticipate more and 18 not wait for a problem to'come up on our tcent door-before 19 we have dealt with it. We have --for example, in operating 20 reactors, we ought to be able to detect deteriorating 21 performance before it gets to the point that it requires a 22 major action. For new plants we ought to have in place a 23 good licensing process.
24 I think there is a feeling that the agency has 25 boon too firo drill oriented and ad hoc approach to the ace FEDERAL REPORTERS, INC.
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2 term planning to achieve policy stability.
3 The second thing you find in this plan is a 4 recognition that we need to differentiate more what we 5 potentially give licensees based on the performance and 6 potential risk instead of treating everyone quite the same.
7 Let's move toward giving more attention to the poorer 8 performers and less attention to the good performers and 9 make a conscious decision to tilt that way.
10 I think in the past there has been an effort that 11 anyone who had a license had about the same level of 12 attention.
13 DR. SIESS: I thought SALP was intended to make (v^}
14 some kind of distinction.
15 MR. DENTON: It is, and I think we are 16 recommending other areas and a conscious decision to keep 17 that idea going, trying to give enhanced incentives for a 18 good performance, and we need to do more toward thinking up 19 ways toward giving incentives for good performance. And I 20 am not talking just about reactors, but I am applying this 21 to all the activities that the NRC undertakes, finding a way 22 to have a more active role of licensees in achieving 23 excellence.
24 They develop structures that would encourage
{} 25 that. You give a lot more focus to research and support of ACE-FEDERAL REPORTERS, INC.
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1 our agency mission.
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2 'A lot of ideas came out about how we might give 3 more focus in the agency to doing research and being sure 4 the results are credible and are used and support our goals.
5 The next bullet is to be sure that the public and 6 all'the people we interact with understand. Talking to 7 people, we find there is a great gulf between what we think 8 we do~in certain cases when we send out enforcement letters 9 and reports and actions and what the public thinks we are 10 doing.
11 We don't communicate very well. We speak in 12 jargon and complex technical terms.
13 DR. SHEWMON: The public is not'the-licensees,
'{~}
14 but just Aunt Nellie or'something, right?
15 MR. DENTON: Yes.
16 DR. SIESS: You don't communicate directly with 17 the public, anyway. You communicate through the media.
18 I would expect to see somewhere something about 19 the media in there, the only way you get at the public 20 outside of Washington, and even in Washington.
21 MR. DENTON: Well, there's a lot of ideas we have 22 got about how to carry that out in the plan, but it includes 23 making sure that we release in layman's terms an explanation 24 any time there are reports that are issued and having the 25 Commission meet with editorial boards of papers and
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1930L13 l'3 157 7'SVbur 1 governors and elected of ficials and recognizing that there -
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2 is a lot more interest' in this' field than.just between-3 ourselves:and you and the licensees.
- 4 I think we are'at something of a low ebb in
'5 publ'ic support for this business we are in, and we need1to 6 explain then why we think what we are doing is proper, and 7 there are a lot of ideas and plans to do that.
8 I want us to - try to be sure we allocate . resources
- 9. relative to risk better, that we have not disproportionately
. 10 allocated our resources. We have got to take a-look hard at
- 11. maybe radiographers, for example.. That is a group where 12 individuals are getting year-in and year-out overexposures.
{} 13 Are we doing enough in that area than focusing.on-some,other 14 areas?
15 'It is an attempt to reexamine all our programs 16 across the board to be sure that we are trying to allocate 17 -- that where there is high risk we can do something about-18 reducing it.
19 I think we have kind of thrown out programs,-
20 safeguards, and reactor safety materials in other areas, but 21 whether or not we have gotten the proper amount of resources 22 in each one of these spots is something that this plan would 23 have us reexamine.
24 Finally, finding a way to put in place inside the
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-f'"jVb u r 1 training, and we talk so much about the importance of the U
2 human factor outside the agency, to adopt the same attention 3 to human factors inside, rotation assignments, and we have a 4 lot of good ideas.
5 The next page summarizes some of the major 6 strategies for reactors and material licensees, but they 7 kind of start with the need to establish standards as a 8 measure of performance. We don't have to do research in 9 that area.
10 We clearly define, if we can, what constitutes 11 good performance. Let me illustrate that for reactors, for 12 example.
13 We gave a lot of thought to standards for reactor
(~/}
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14 performance and said what do we really want. Well, maybe 15 among other things, we want a low frequency challenge to 16 safety systems. We want high availability for plant safety 17 equipment, highly trained, motivated, and supportive 18 personnel.
19 We want learning from others' experience so we 20 can develop a learning curve and load sensitivity of the 21 design to challenges. So we have tried to como up with 22 somewhat stronger measures for performance in other areas or 23 recommend that performance indicators be developed.
24 Then we want to structure our inspection and
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-2 We want to encourage excellence in the licensee's-3 performance, continue to recognize that there is a' lot of 4 uncertainty with regard to accidents, and then finally make 5 sure that all the attention we are getting in' this area does f 6 have some direct relationship to'what we can do with riskiin 4
7 that area.
8 MR. EBERSOLE : Harold, may I ask you, my 9 observation is that we put up our reactors more or loss like 10 a kid's party where overybody runs up at once and puts -his -
11 tail on the donkey, and that creates a monstrosity of 12 patches, patchwork, and attempts to plug up the holes in the ,
(} 13 14 logic and the rationale for shutdown and whatever.- ,
I don't hear,you saying that we are going to l
15 change our view toward looking at the focal issues of 16 reactors, that we won't consolidato and hopefully simplify 4
17' and produco designs which are intrinsically good rather than 18 thoso which are mado good af ter they become. intrinsically 19 ill-founded.
20 MR. DENTON: The ones I have just mentioned aro -
f
- 21 for the existing reactors that are out there and built. For
! 22 future licensing, I would hope we could do that sort of 23 thing.
24 On the next page, pago 7, it talks about our
{} 25 goals and strategios for future plants. We have said for 2
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1930'13 13 160 r"SVbur 1 ones under construction let's be sure that we have got G
2 quality construction when they are finished, and let's 3 really focus on the transition from construction to 4 operation, and you notice a number of strategies in the plan 5 ' are different from what we do now on how to make sure that 6 when they go into operation that they go in smoothly.
7 We have got to prepare now for the future plants, 8 as you point out, Jesse, that we have got the right program.
9 Among the things that are covered in the plan are 10 lifetime extensions over a number of years. Yankeo has got 11 25 years of operation. A number of plants, we are talking 12 about extending their life. We are going to get requests
() 13 14 for decommissioning, so we are going to have to focus in that area.
15 Standardization is a big topic in advanced 16 reactor design.
17 Those areas are ones where we nood to move on and 18 have programs in place and settled.
19 We nood to put in place a regulatory program on 20 high level and low lovel wasto.
21 The next pago summarizos some major features for 22 people other than licensoes.
23 Wo really nood to promoto coordination of stato 24 and local governments much better, and we have started
{} 25 trying to do that.
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r ^.Vbur 1 Inform the public through the media how things V
- 2. are going on so that they are not surprised, and we have got 3 a number of ways to try to open the door to what we are 4 doing.
5 Improve the planning of our own programs, 6 improvements in the management area.
7 And, finally, continue the independent safety and 8 judicial oversight boards, such as yourself, the licensing 9 boards, and others.
10 With regard to advanced reactors, one of our 11 strategies is to reolire as a minimum at least the same 12 degree of protection of the public and the environment as is
'S 13 required for the current generation of reactors, with the (G
14 expectation that advanced reactors will provide enhanced
. 15 margins of safety and utilize simplified current, passive, 16 or other innovative things to accomplish the safety 17 functions.
18 That is the goal.
19 Ilow we achieve that is to be decided, but you 20 will find the strategic plan is our goals. It is not always 21 clear how to achieve these or whether they even can bo 22 achieved, but those would be the goals by which wo direct 23 the Staf f to try to chooso.
24 I think you have got copios of the plar. Itsel f, 25 which is a more substantial document.
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2 is. being used in developing the current five-year budget 3 plan, and no doubt a new team will be formed here shortly 4 this fall to begin revising the strategic plan for next 5 year's budget cycle.
6 In sort of a nutshell, it has - been a very good
-7 effort. Probably t2 e main advantage of this effort is it 8 got the senior Commission Staff together several times all 9 in the same room for one of the few times I can remember. i 10 : Seldom do we get everybody together because it is such a big 11 commitment of resources to do that.-
12 It forced us all to go around and understand the ,
F
.() 13 entire Commission program and not just the individual
'14 program the person is responsible for. That in itself was-15 an extremely good action.
16 As our consultants point out, we don't have 17 detailed analysos of those strategies or contingency 18 planning. This was the first effort. 'I think it is a good L 19 first step. It is far from what you would find in IBM or 20 Westinghouse or somoplace, but it is beginning, and I think l
21 it is what the Chairman had in mind as a first stop.
22 DR. KERR Mr. Rood.
23 MR. REED: I road the document plan, and I como 24 away with one concern, and it is an old refrain. I wroto 25 down another goal here, and I will try it on you.
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./"$Vbur 1 It says, search out.significant design
. (_)
2' vulnerabilities in operating reactors and efficiently 3 correct them.
4 I just feel that that is a very important thing, 5 and I feel that there are some vulnerabilities of reactors.
6 Forget the cost-benefits that need to be corrected.
7 DR. MOELLER: You have mentioned several times in i 8 the document that there is a need for better relations with-,
9 stato and local governments, Indian tribes, and so forth. j
10 In a recent paper John Aherne pointed out that we 11 are having so many problems with emergency planning, yet No 12 one has suggested or no one within NRC at least, so far as 13 he knew, was conducting any research on how you work with s
{
14 state and local groups or how you stimulate them to ,
15 cooperate or is there a difference approach to achieving '
16 your goals.
17 It soomed to me to be a pretty good suggestion.
t 18 I would not know specifically how to undertake research 19 there, but I would hope you would consider it.
20 MR. DENTON: I think we felt in general that the 21 term "rosearch" had boon construed too narrowly -- the '
22 hardware rosearch -- and we are finding a number of areas in 23 which research can work on all the unknowns of the agency, 24 management unknowns to any kind of unknowns.
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1 possibility.
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2 The way we are trying to attack it is we have had p 3 liaison officers in each region, but the tasks, as they see
- 4 their jobs, have not been sharply defined, and we have had 5 several meetings now to try to sharpen up to be sure that we 6 get out and get in touch periodically with every state in 7 the U.S. to find out what they are thinking about programs 8 we are interested in, and we are trying to keep them much 9 more closely attuned to state concerns.
10 Likewise, we are trying to go back and tell the 11 . states about actions that the agency may be about to take 12 because I think the states think they have not gotten all
(~)
\/ '
13 the attention that they need.
14 So in some states we have established a pretty 15 good rapport. The states vary greatly in their interest in 16 this.
17 DR. REMICK: I have two questions, Harold.
18 One would look at a utility licensee. You have 19 goals and objectives, as I find many of them do, and you
- j. . 20 will find that those' are carried right down to senior
.\
21 management. There are objectives for this year that they 22 are going to be evaluated against.
23 Do you plan in the agency to carry that down at 24 least to the SES people so some of these goals and 25 objectives will appear in their evaluation?
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1930 14 14 165 e'"Vbur 1 MR. DENTON: I think we talked about that. Let
()
2 me ask Jesse to respond.
3 MR. BUNCHES: I think the intent is that the 4 five-year plan will become the basis for SES contractor to 5 be part of the senior management and senior contractor. I 6 think the intent is to be able to communicate the goals, the 7 strategies, the programs, and the resources and actually 8 assign them to an office as we assign pieces to the 9 divisions down to the branch.
10 I think the intent is to use this document not 11 just as a guidance document but also as a management 12 document to hold people accountable.
(~'; 13 DR. REMICK: The second point about the A._/
14 development of personnel.
15 Dade and I were talking about this a little bit 16 in the elevator at lunch.
17 I remember writing a letter to Ed Mason when he 18 was a Commissioner. At that time I was traveling with NRC 19 personnel in Operator Licensing. I was concerned that 20 people didn't seem to have a broad perspective of what not 21 only was going on in the agency but what was going on in 22 other agencies.
23 We see that. We are kind of in a somewhat unique s .24 position here. We see all the various offices and are
<' 25 amazed from time to time what one office doesn't know is (3 /
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1930 14 14 166 r"'Nbu r 1 going on might be a good type of thing in another office.
V 2 Are there any objectives in your goals here to 3 try to get cross-communication across the agencies?
4 Not only does it make a better, more uniform 5 agency, but people like to have a feeling that they know 6 what is going on and they aren't in the dark.
7 Are there any specific objectives that have been 8 defined to try to improve knowledge and communications?
9 MR. DENTON: I think there are, and we have 10 already begun them. This has prompted a number of the 11 senior managers to go back and face those task questions.
12 We asked ourselves, when we promote someone what 13 V;
/ would be the desirable characteristics of a person to 14 promote? We said, how do we find this out? Let's go 15 interview people.
16 So we interviewed inside and outside the 17 agencies, former Chairmen, a lot of NRC employees, and among 18 the key arera that came back is diverse experience, that 19 what you would want in any job is someone who has a broader 20 outlook than he has always worked in the thermal hydraulics 21 branch. You want someone who has done several jobs and can 22 relate to all the agency goals.
23 So I think you are going to find that in our 24 future personnel development plans that it will be required t'~T 25 to move ahead in this organization that you will have to V
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2 year after year you should not expect to get promoted.
3 That will become part of our structure, and I 4 think you will find a lot more rotational assignments 5 between offices and between regions and between regions and 6 headquarters. We may even end up defining, like the Navy, 7 that you have got to get your ticket punched in several 8 areas before you will be qualified at the next level.
9 Hopefully, that will remove some of the 10 dif ferences that you see in approaches between one branch 11 and another branch.
12 I think if we can all get in the same building it r~'; 13 will be a lot easier, too.
V
-14 DR. REMICK: I will give you one example. We 15 found that one office did not know anything about performing 16 base training. It was not NRR, but it was another office.
17 But it was surprising that they did not know what has been 18 taking place in the last four or five years.
19 MR. DENTON: I don't think we communicate well.
20 Everyone tends to work on their own little problems. It 21 seems that the problems we have got with the regions, they 22 are out there worrying about safety as they see it but they 23 don't level with us on the major topics.
24 DR. SIESS: Harold, on page 4 of your handout,
(~) 25 the heading is "Overall Goals." The last item is assure
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! 2 Would you enlarge on that just a little bit and 3 mention how you think the ACRS, the Congress, the National 4 Academies, and so forth -- what is the scope of that item?
5 MR. DENTON: As we developed the major goals, we O came up with the thought that our responsibility includes 7 many controversial areas of inspection, enforcement, legal 8 matters, and that we need oversight in order to make sure 9 that we are doing it properly.
10 We think then that it is important to maintain 11 special independent reviews and investigations. So we 12 developed some strategies, which largely are to continue the
('l 13 kinds of -- continue the ACRS, the licensing boards,
%)
14 determine the need for an independent board to advise on 15 waste management, continue to maintain the capability to 16 evaluate operating experience, continue to maintain the 17 capability to investigate wrongdoing.
18 Those kinds of things need to come into play, and 19 include those groups whose main job it is to oversee the 20 adequacy of the Staff.
21 DR. SIESS: Have you got any idea what might be 22 the upper bounds to that?
23 MR. DENTON: In what sense?
l 24 DR. SIESS: I think you named about six sources 1 p
v 25 of independent review, and you didn't really finish the ACE FEDERAL REPORTERS, INC.
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2 Is there some point that you might think you 3 would have enough? How would you know when you had enough?
4 Would people stop criticizing you?
5 MR. DENTON: I think that is a que'stion being 6 debated by Congress right now as to whether we need more.
7 DR. SIESS: There are independent reviewers, six 8 of them. .They are independent of each other.
9 MR. DENTON: We were not able to put a lot of 10 strategies into that area. When we looked at the plan, we 11 realized that these groups.have resources. They perform 12 valuable func. ions, and the plants should~ recognize their-13- role in-the process.
L'~)T .
14 DR. SIESS: And these are not only technical.
15 reviewers. What you mentioned covered other things.
16 MR. DENTON: Chi that point the question has been 17 raised whether we need a statutory inspector general. That 18 bill has been introduced in both houses, and several of our 19 appearances before Congress lately have dealt with that 20 topic.
21 DR. OKRENT: I would like to.look a little bit 22 about the way the public fits into all of this. I notice 23 that you have something about keeping the public informed, 24 but I want to look at another aspect.
(} 25 One might have guessed, wrongly I think, that ACE FEDERAL REPORTERS, INC.
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r 7Nbur .1 given the Commission adopting the rather stringent safety l A_J ;
'2 goals and the' Commission then making a finding in the safety.
3- policy statement'on severe accident policy that it seems 4- from the existing evidence there is no reason to think our -3 i
5 existing reactors aren't in shape, that they adequately 6 protect the public health and safety, that the ' public would 7 be reassured, and that instead of -Mr. Aherne reporting in 8 his recent Science article I think that 70 percent of the 9 public are against building any more reactors, that the 10 number might be'the other way around or something, or at 11 least with the proviso that if they could indeed make 12 cheaper electricity or give us less dependence on something, 13 or whatever.
}
14' But that doesn't seem to have occurred.
15 ~. Then just adding a different kind of perspective, 16 I remember hearing it said that when Peter Hunt was -- I
'17 guess he was with'the FDA -- every year supposedly they 18 asked three questions. First, what is the public most 19 concerned about; secondly, what do we think the most 20 important thing is to do; third, how much resources do we 21- have? And then with this mix of input, they somehow decided 22 what to work on.
23 I don't see in the plan or in fact in any of the 24 agency's actions an effort to understand in sufficient depth 25 what is the source for this public disquiet.
{
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-1930 14 14 171 7'")Vbur 1 And there is no one public, but apparently it is
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~
2 broad enough so that it isn't just the PTA or whatever or 3 the League of Women Voters or whatever.
4 I am wondering whether the NRC thinks in some way
.5 it should try to find out, keep in mind public thinking, and 6 ask in what way, if at all, it should influence what the 7 agency does.
8 This morning we heard somebody come in and say, 9 well, we are doing this all in public, and I asked who is 10 going to know-about this. Well, the industry said it may be 11- one or two public interest groups. That to him was keeping 12 everything_public, and I think in the legal sense he was,
{} 13 14 but in the sense that Mr. Aherne was talking about -- and he gave a talk a year or two ago, saying that a certain trend 15 was inevitable because of public opinion -- I think now the 16 public opinion has gone further down the road.
17 Are there any thoughts in the agency in this 18 regard, or is it just something you say, that we are-an 19 independent agency, we have to decide what we think is 20 right, and that is it?
21 MR. DENTON: We didn't feel in this effort that 22 we could restructure the agency to provide, say, a general 23 advisory board. We are trying to develop a plan that could 24 be implemented by the existing structure and without 25 statutory changes, and so forth.
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,7'Nbur 1 But one goal is to provide timely, accurate, V
2 complete information to the public, and what we are trying 3 to do in that area -- take the EPRI standard plants -- we 4 have sont that to every head of engineering in the U.S. We 5 have sent it to all my counterparts in foreign countries, 6 and we have sent it to all the state officials who are our 7 contacts on nuclear matters.
8 That is an attempt to reach a broader public than 9 just the trade press.
10 We are going to start attending and participating l
l 11 in public utility commission association meetings, radiation 12 control officers' meetings and try to explain what we do.
13 It does seem that compared to many countries we l f]
v 14 get a lot of input from Congress. I was just up in Canada ;
15 recently visiting the Pickering and Bruce sites up there, 16 which is a good example of standardization. I was talking 17 to the Atomic Energy Control Board. They said that they 18 have five members, one chairman. The other four members are 19 part time. They meet six times a year. They make one 20 appearance before their Congress per year, and it is 21 striking the differences between that system and ours, in 22 which we get a lot of input from Congress, in which they 23 evaluate how well we are doing this or that.
24 So we didn't try to come up with any new way to (3 25 get to the public except to come up with a lot of ways to LJ ACE-FEDERAL REPORTERS, INC.
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1930 14 14 173 Vbur 1 outreach to people that we just maybe hadn't found the way 2 to deal with properly.
3 It is clearly something we have got to do better.
4 and when I talk to the journalists out there, the networks, 5 and newspapers, they frankly can't understand often what the 6 NRC does. It is just too complex, and we don't make the 7 effort often to explain it.
8 And what they would like to see promises much 9 more of our time and measure of attention in trying to 10 explain to them what we intended to do and what we did do.
11 I don't know if I have answered your question, 12 but we didn't try to come up with a structure to go ask 13 every interest group what they thought or advisory
[}
14 committee, but maybe that can be done nuat time around.
15 DR. MOELLER: On page 11 of your report, in one 16 of the bullets, you stated, if I am interpreting it 17 correctly, that the NRC would cooperatively with other 18 federal agencies attempt to stimulate DOE to sponsor a 19 design competition for a standard plant.
20 Could you comment a little more on that?
21 I know DOE is working along on smaller passive
! 22 units, and so forth.
23 Would this be an extension of that or something 24 now?
25 MP. DENTON: The concept has not been fleshed
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1930.14 14 174 f~'Nbur 1 out. Many of these are more goals than concrete proposals, L) 2 but the idea would be that perhaps for $25 million or so the 3 government would sponsor a design competition. They would 4 put money out to the private sector. They would have on the 5 review board -- and perhaps DOE would fund it -- the 6 Department of Labor, the Department of Commerce, any 7 government agency that has an interest in safe, reliable, 8 economical nuclear power -- and hopefully get some proposed 9 designs back, and the NRC role in that process would be to 10 provide a safety review design and perhaps certify that 11 design so it was an attempt to respond to the criticism that 12 really nothing is being done in the U.S. with regard to
(^T 13 standard design.
O 14 There is a feeling in some quarters that no money 15 is being spent in the U.S. Except for the ABWR and the 16 APWR, there is not a lot of horizon that is being worked on 17 at this time.
18 But we didn't think the NRC itself should push 19 this. That is where we said maybe we should get Energy and 20 someone interested in these projects.
21 So it is that kind of a goal. But how it would 22 be achieved or whether it would, we don't know.
23 DR. KERR: Mr. Shewmon, do I see a question 24 stirring within your breast?
/"S 25 DR. SHEWMON: No.
()
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[1930'l4114- 175 Of '?Nbur 1 DR. KERR: Further questions?
Q( 2 .(No response.)
3 DR. KERR: Harold, in following up somewhat on 4 your actions with the-state and local governments, it is not 5 clear to me whether you were emphasizing a relations change, 6 -- which would be one thing, or whether you wanted more
=7 participation by those groups in decisionmaking, or perhaps 8 some of both.
9 Could you elaborate a bit?
10 MR. DENTON: It is a fascinating evolution to 11 watch. That is being a bit long-winded, but let me mention
[ 12 'what is going on.
l
/~T 13 Many states want to exercise more participation
(/
14 in our process. They want to accompany NRC inspectors.
15 They want resident inspectors at the site. They want to be 16 better informed about actions we are taking with licensees.
- 17. . But many states don' t want ' to go beyond 18 oversight.
19 Now, the governors have formed a task force and 20 many of the well-known Presidential candidates are on that 21 task force, and it has a number of proposals that would seek 22 legislation to enable the states to regulate matters which 23 we now regulate.
24 It would give them, for example, veto power over 25 operations regarding emergency planning. It might give them ACE FEDERAL REPORTERS, INC.
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.r )Vbur. I total authority for ASME codes.
L) 2 That is being debated within state organizations.
3 We are trying to work with the states to provide them as 4 much oversight and participation in that process as we can 5 without relinquishing our present statutory responsibility.
6 Illinois, for example, is an interesting state if 7 you look at'how they get involved. They have pressurized 8 chambers around every plant in the state now, headed back to 9 a response center. That was done by Mr. Gustafson, formerly 1 10 from Argonne.
11 Then they said, well, we may not need an 12 emergency. Let's put in stack monitors.
(^h 13 So the' state has paid for first class stack
\_)
14 monitors for all 13 facilities in the state.
15 They have a fleet of vans which are well-equipped 16 with radiation monitors.
17 Most recently, they installed data links with all 18 the process computers in all the plants in the state.
19 When you visit their control center, they have 20 got more information displayed from afar than we do, and we 21 are still running on telephonic communications. So they 22 have detailed information on the status of every plant in 23 the state.
24 They have a large staff. They have about 200
(~) 25 people in the state that monitor this.
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( 7Nbur 1 So it is an interesting evolution of the state,
~J 2 and of course they then get interested in all the problems 3 we get interested in.
4 That is a state which has probably gone the 5 farthest in trying to independently assess the safety of 6 plants, and I think they are moving now toward resident 7 inspectors in all the units.
8 DR. SIESS: How do you think that will improve 9 safety?
10 MR. DENTON: I didn't.
11 DR. SIESS: You used the word " safety" in the 12 preceding sentence.
! 13 MR. DENTON: Were you asking me a question, how
(~/')
x._
14 do I think that will improve safety?
15 DR. SIESS: Yes.
16 MR. DENTON: It provides the state a parallel i
17 knowledge of any releases. I hadn't asked them to develop a f 18 competing program. The state did it on their own. They i
19 don't have to rely on the federal government, and they don't 20 have to rely on the licensee to assess any release that 21 comes out of the plant.
22 DR. SIESS: Do you think it would improve 23 emergency management?
24 MR. DENTON: Emergency management? They are in
(~s 25 a very good position with regard to the data link if you sit
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~~Nbur 1 there and look at the parameters on operating plants, they V
2 don't know which ones-to really focus on either, and I 3 understand they have got contracts with several universities 4 in the area and Wisconsin to try to help them understand how 5 they might monitor an accident.
6 I mention that only in the state context as one 7 state that has moved aggressively and is moving to take 8 responsibility in a number of areas.
9 Ultimately, I think some other states are quite 10 content to have the federal government continue to do what 11 they are doing. It is a spectrum.
12 DR. SIESS: Has Illinois taken responsibility 13 other than what they would have under the emergency plans?
(~')T 14 MR. DENTON: That is correct. But they are 15 actively proposing that there perhaps be some movement on 16 this.
17 DR. SIESS: As a resident of Illinois that lives 18 30 miles from a nuclear plant and one mile from a railroad, 19 I think I would be much happier if they took the same money 20 and spent it on hazardous cargo knowledge. So when a 21 derailment occurs they would know whether to evacuate me or 22 not.
23 I will leave that there.
24 MR. REED: It looks like you have paid some
(~3 25 pretty good taxes for all this inefficient operation, too.
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t 1930 14 14 179 f"i1Vbur 1 51R . DENTON: It comes about through state laws LA 2 that require a subsidy for operating this nuclear safety 3 function.
4 I mention it not to critique Illinois, but just 5 to illustrate a very aggressive state.
6 Vermont I think has hired someone now to be full-7 time for the governor on oversight of Vermont Yankee, and a 8 number of states have gotten concerned and have begun to 9 hire staff to keep up with what is going on in those plants.
10 I mentioned Illinois because it has probably 11 moved the furthest.
12 DR. KERR: Do you know enough about Illinois'
(~)
~j 13 system to know whether the relationship that exists between 14 this group and the utilities is adversarial, or do you have 15 a feel for that at all?
16 MR. DENTON: I really don't have a personal feel.
17 I presume the utilities resent having to pay it, but I don't 18 know.
19 DR. KERR: I was just curious as to what the 20 experience of this group of people had been. Are they 21 impressed, ala rmed?
22 MR. DENTON: I think it is too early to tell.
23 For a long time the state was under a salary cap, and 24 apparently that gave them some dif ficulty in hiring the 25 people they wanted.
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1930L14 14' 180 1 Recently, the state lif ted the salary cap, and I c(")Vbur
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2 now notice they are recruiting NRC employees. So they are
'3- ' building up~a-cadre of well-qualified people.
4' 'I know of another case in a state out West where
-5 .there is an excellent relationship between the state 6 inspector onsite and the licensee and the NRC. So there are 4 7. examples where if the states wants to be better informed E that it. has worked out well.
9- I think there are also some examples of where it 10 'has worked out poorly, and we have had difficulty in
'll. maintaining'everyone's responsibilities. -
12 There is a' lot going on.in'the states, and the 13 states are.giving this whole nuclear area a lot of increased' 14- attention, and I think it is because of the confluence not:
15 only of reactors'but low level waste, Thigh level waste, and 16 .just a general sensitivity to the nuclear matters in general'
- 17. in the' states.
18 DR. KERR: Our time is about up. Is there maybe 19 one more question?
f 20 (No response.)
21 DR. .KERR: We appreciate the lecture and coming 22 in to help us on this.
, 23 MR. DENTON: Thank you.
24 DR. KERR: You have kicked off quite an 25 enterprise by suggesting that the Commission move this way.
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i 1930 14 14 181 7 '7Xbur 1 (Recess.)
DR. KERR:
~
2 The next item on the agenda is a
-3 discussion of the implementation of one of the items 4 contained in the severe accident policy statement, which 5 promised to formulate a plan for systematic examination of 6 operating nuclear plants and look for outlier plants.
7 The Severe Accident Subcommittee met with the 8 appropriate staff people on the 28th of May to discuss a 9 generic letter in draf t form that is being discussed and 10 proposed and has gone through the approval chain, which asks 11 individual licensees, operating power plants to carry out a 12 systematic review and gives guidance as to the nature of the
'~) 13 review and to the approaches that are deemed acceptable to Gl 14 the Commission Staff.
15 The presentation by the Staff will be, of course, 16 abbreviated compared to that we received. I believe it was 17 the consensus of the subcommittee members, and we had a 18 fairly good representation at that meeting, and of the 19 consultants that the so-called front-end treatment; that is, 20 that part that would be done in the PRA from the initiation 21 of the accident to the onset of core damage, was perhaps in 22 better shape compared to the back-end treatment, which 23 begins somewhere after severe core damage sets in and goes 24 through the performance of the containment systems and is
'~T 25 released to the biosphere.
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(")Vbur 1 And it indeed, I think, was the opinion of some V
2 of the members' of the subcommittee and of the consultants 3 that'in its existing form it would not accomplish the-4 purposes that were considered necessary.
5 I won't comment any further, but I-will ask, 6 before I turn this over to the Staff members, if there are 7 comments by members of the subcommittee or by other members 8 of the committee.
9 Dr. Okrent.
10 DR. OKRENT: I assume the comments you just made 11 are with regard to the proposed method from IDCOR. There 12 are PRA methods which I guess are'able to deal with it from 13 the back-end in a tolerable way.
()')
14 DR. KERR: We were going to deal with that as an 15 enclosure in the proposed generic letter, a discussion of 16 the way the proposed containment performance can be treated 17 by licensees.
18 DR. OKRENT: Using the IDCOR method?
19 DR. KERR: The IDCOR method is only one possible
, 20 niternative named by the Staff that is available to 21 licensees.
22 DR. OKRENT: I guess it is my impression that if 23 someone were to do what I would call a good Level-2, meaning 24 up to the point including containment release but not the l
^S 25 consequence, public PRA, it is thought that while there (O '
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~TVbur 1 still are some issues which we don't really know enough 2 about except to make subjective judgments, one could i
l 3 probably, I think, do a job that within the state of the art 4 satisfied the severe accident policy statement.
5 I think the problem arises, as I understand it, 6 in the less specificity and some of the constraints that one 7 finds in the IDCOR approach.
8 Am I wrong?
9 10 11 12 i
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' TVbw 1 DR. KERR: I repeat, there is a guidance gj-2 statement. One possible approach that is is listed is the 3 use of a standard as found in the PRA; however, that was not 4 the only approach that was suggested. And it was the 5 consensus, I believe, of.those present who discussed this, 6 that that approach would probably accomplish one of the 7 objectives, given state-of-the-art PRA review, but it almost 8 certainly would request outside consultants who would do the 9 PRA, thereby one would lose what some of, at least, felt 10 would be an important value of the analysis, namely, that 11 you would have a very significant number of people within-12 the utility who became familiar with the severe accident fi 13 possibilities and the sequences and the information would be v
14 available during the course of ~ carrying out the analysis.
15 DR. OKRENT: Until the utilities understand their 16 plents and how they can get into trouble and how these 17 accidents can be addressed, it is my current impression that 18 if we were to give approval, if the Staff gave approval to 19 the IDCOR method and these others next week, the bulk of the 20 utilities would hire Westinghouse or somebody to do much of 21 the analysis, that the utilities would be providing detailed 22 descriptions of the plant and a little bit more, that most 23 utiliites would not be in a position t.o carry through the 24 IDCOR approach.
() 25 I think there are companies that are ready to ACE FEDERAL REPORTERS, INC.
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2 DR. KERR: I think the NRC Staff perhaps will 3 speak to this, but I think that it is agreed that a utility, 4' even-with limited experience, would be able to. contribute 5 significantly to the front end part of the treatment. l 6 DR. OKRENT:
I agree. More to the front end than 7 the back. Absolutely.
8 DR. OKRENT: Further comments or questions?
9 (No response.)
10 DR. KERR: Mr. Sheron.
11 MR. SHERON: Thank you.
12 As you said we were down here May 28 briefing the
(') 13- subcommittee on this program.
14 Today, Frank Coffman, Acting Chief of our 15 Reliability Factors Branch will be making the presentation.
16 Just a note on our schedule. Right now, we would 17 like to get the letter implementing the individual plant 18 examinations out by the end of July. This would entail 19 going to CRGR, hopefully, by the end of this month, before 20 the end of this month and going to the Commission in early 21 July.
22 One thing we would be hoping to get from the 23 committee before the end of June is a letter that 24 essentially says that the process we have in place is good
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1930 16 16 186 f~',Vbw 1 forward with the IPEs at the plant.
v 2 Dr. Okrent.
3 DR. OKRENT: In the material you supplied, as you 4 know, there are a large number of places where the Staff 5 says the proposed IDCOR method has to be implemented one way 6 or another, but in reading it, I found I would have 7 difficulty in judging how much additional effort the Staff 8 or how many different phenomena, or whatever applied, are 9 thought to be relevant.
10 In some cases, it is sort of clear that we should 11 use something like the beta method, or whatever.
12 Do you feel that you are ready, in fact, to bless
( ,') 13 the IDCOR method with those sort of what I'll call general 14 qualified conditions, that this is, then a sufficiently 15 well-defined method, or are you assuming that this is going 16 to be talked out, or one of those things that are left in 17 somewhat general terms?
18 MR. SHERON: I would answer that we think it is 19 defined well enough to go forward and to ask the utilities i 20 to implement this.
21 My guess is, we are going to learn, as we go 22 through this process -- we are going to learn there are hard 23 spots that they require more clarification from the 24 industry. There are areas that we are going to have to (Aj 25 study perhaps a little harder, because we realize, that as ACE-FEDERAL REPORTERS, INC.
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/~' V I we go through this, we learn new things. I don't think we
(> bw 2 are trying to characterize that the guidance we are giving 3 the industry is fool proof or perfect, and that we've got 4 everything down to dotting the last "i" and crossing the 5 last "t."
6 I wasn't at the last subcommittee meeting. I did 7 read the transcript, and I think it was pretty clear at that 8 meeting that there's still a lot of questions that remain 9 about the implementation of this program, thresholds, and 10 the like.
11 I rally think that we are not going to understand 12 what the real problems are until we try and get this thing i Iv ') 13 off the ground and implemented.
14 I don't know if that answers your question 15 perfectly.
16 DR. OKRENT: No, but I will come back and ask 17 IDCOR some questions.
18 MR. SHERON: Just one other thing. We are 19 planning, once we issue the letter, to initiate regional 20 meetings with the utilities in the region and explain to 21 them the IPE method, the letter, and hopefully answer any 22 questions that they have.
23 DR. OKRENT: If they are not answered here, I 24 don't know what more you are going to tell them, because if
() 25 you had more to tell them, I presume it would be there.
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1930 16L16 188 1- But let's go on.
'(v~'Vbw 2 MR. SHERON: Okay. I have nothing else, other 3 than we did bring down the ' Staff that has been involved.
4 Dr. Rosztoczy.is here, though he is not directly responsible 5 in'this area anymore, he'has come down to help us. Dr.
6 Landry and Dr. Burkett, from Brookhaven are here.
7 And Frank?
8 (Slide.)
9 MR. COFFMAN: I plan to-cover these topics, the 10- first four topics on this, which is Vugraph number 1 in the 11 package that_you should have in front of you.
12 (Slide.)
.() 13 'Just briefly, by way of orientation, the Severe 14 Accident Policy Statement by itself had about five action 15 items, two of those relating to new applications,-two 16 . relating to existing plants, and one, as needed, action 17 items, as needed.
18 As far as changes in rules and regulatory
, 19 practices, what we are focused on in the discussion today,
- 20. out of the Severe Accident Policy Statement is this item
- 21 here on the systematic approach for the examination of 12 2 individual plants.
- 23 (Slide.)
24 The way the systematic examination is to be
() 25 implemented, the vehicle for it is to initiate, by a request
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(" . I letter to the owners of all existing plants, that they M]Vbw. .
2 systematically examine their plant for severe accident 3 vulnerabilities. :
4 MR. EBERSOLE: I wonder if you clarify a point 5 for me. I have always had a little trouble, and maybe I am 6 the only one, in looking at the severe' accident problem in 7 this context. You can say I arbitarily postulate.the 8 beginning of a severe accident, regardless of the reason for 9 that occurrence.
10 Now I am going to look at what happens. I am 11 obligated to do that, just like I used to look_at the large 12 LOCA.. I didn't say how it occurred or why or what the
- () 13 probability was. I said it will occur, and I must deal with 14 it,-okay? .That is-one way. Or you can start with lighting 15 the match off the plant someplace, watching the forest fire-16 .take place and then arguing up to a point, GHA may not ever 17 have it.
18 Tell me, in a severe accident study, which method 19 did you take? Did you start with the match or with the j '20 assumption you are going to have a severe accident? .
21 MR. COFFMAN: The analysis of a plant includes 22 steps whereby the utility is to identify what are the I
. 23 possible initiators of a severe accident scenario.
24 MR. EBERSOLE: That embodies all the other kinds 25 It is a complex
) of less than severe accident initiators.
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~' V 1 problem.
- (Q bw 2 DR. KERR: He will try to answer the question.
3 MR. EBERSOLE: He wants you to go. ahead without 4 me butting in.
5 (Laughter.)
6 MR. COFFMAN: I was trying. I don't know, you 7 will have to judge, how succesfully, but it was simply that 8 they look at all the initiators-that could lead the plant 9 into severe accident scenarios, and it may be for that 10 particular design that some are sufficiently infrequent that 11 they can be ignored, but the intent, in the implementation i
12 of the severe accident policy is to assure that the
() 13 initiators, the possible initiators for that plant have been 14 ' addressed; however, there is a scope limitation, which I-15 will get to in about the third or fourth Vugraph, which 16 deals with the distinction between internally initiated 17 events and those that are externally initiated.
18 MR. EBERSOLE: But the next question was this.
19 What that does, it escapes, if you do that. Well, I will 20 ask you. You can, through that method of analysis, go 21 through the initiators and come to the conclusion that a i
22 severe accident probability is so low, perhaps for the 23 boiler, that you don't really need to consider a really 1
24 severe core melt and vessel failure, or is that within the
() 25 scope of the severe accident work?
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-I'"Vbw 1 MR. COFFMAN: The severe accident policy:
- (m) 2 emphasizes the search for both prevention and mitigation, 3 not'to the exclusion of mitigating actions that can be' ~
4 taken, because the likelihood of occurronce is so low.
5 MR..EBERS0LE: You can say, then, you are not 6 forced into arbitarily saying there will be a core melt and; 45 7 vessel failure. 7 t
8 MR. COFFMAN: .No, you are'not arbitarily a'ssumingl 9 that you've got core melt and vessel failure.
10 MR. EBERSOLE: Okay.
11 MR._COFFMAN: The basis for the generic letter.is 12 in the work that was done?in the preparation of the
() 13 Commission's Severe Accident Policy Statement, where the .
14 conclusion of the Commission was that there-is a c need to L 15 ensure that no vulnerabilities to severe accidents exist at 16 individual plants. So in implementing this, the' Staff is
~17 relying upon 10 CFR 5054 to make a request. We are 18 recommending that that request be made by the Director of 19 NRR'to all utilities. i 20 DR. KERR: Mr. Coffman, to make sure that I 21 understand your response to Mr. Ebersole, I don't-think your 7
22 response' meant to imply that you would accept an analysis7 23 from a utility that analyzed all the sequences, and their 24 probability is so low that we don't have to demonstrate
() 25 anything in the matter of containment. You would not accept' ,
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~',Vbw 1 such an analysis, would you?
v 2 MR. COFFMAN: No.
3 MR. EBERSOLE: You see, that is a different 4 answer.
5 MR. COFFMAN: I didn't mean to confuse you with 6 ,. ,that.
7 MR. EBERSOLE: It is like the large LOCA. You 8 have an obligation say I don't care how low the probability 9 is. I must deal with it.
10 DR. OKRENT: Jesse, I am going to come to Mr.
11 Coffman's possible aid, by saying I doubt very much that any 12 of the plants have so low a frequency of core melt, j[-)
13 including all initiators, that it is not relevant to look at 14 containment performance.
15 I will make a flat statement.
16 MR. EBERSOLE: Then that leads you into the
'\, L i 17 arbitrary postulations.
18 DR. OKRENT: No, they don't arbitrarily postulate 19 it, because different scenarios lead you into core melt in 20 dif ferent ways, with different things functioning, et 21 cetera.
22 MR. EBERSOLE: You have to characterize the 23 individual core melt progress.
24 DR. OKRENT: Exactly.
() 25 (Slide.)
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to identify these y e. . r-4 individual plan,t vulnerabilities, and as we were talking, a 5 for both core damage ~and containment performance and to
~
6 identify pote tial. improvements for an individual plant to respo'ch to severe accidonts.
~
7 If'the goals of tne IPE 8 includ having the-u'tility evaluate the means for improving 9 the plant and improving the reactor systems, the support 10' ofstems that prevent againstxcore damage and to improve the 11 containment performance, given a severe accident scenario, 12 but the primary point is that we are asking the utilities to j 13 evaluate the means, to improve them, and then to implement 14 improvements and any corrective actions.
15 That is, the important part of the IPE is that a ,
a 16 the utilities incorporate the knowledge and the insights b}. 17 that they have gained from performing a systematic h' 18 examination into something that we are calling an accident 19 management scheme or accident management plan, which goes to 20 thepoint of identifying organizational responsibilites 21 during the postulated severe accidents, identifying the
. 22 necessary operating procedures, assuring that training 23 programs include the preparation for such accidents, the 24 identification of needed instrumentation and their survival
') 25 requirements.
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(~'Vbw 1 I would like to come back and amplify on this
(.!
2 aspect in just a few minutes.
3 4
5 6
7 8
9 10 11 12 (O
%J 13 14 15 16 17 18 19 20 21 22 23 24 m
25
( ).
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(~'ybw 1 MR. EBERSOLE: Let me ask one question following a
2 Dave's observation. You said that you are not going to find 3 the probability of core melt so low that you are not going 4 to say it can't happen. That suggests to me that you are
.5 also going to look at what I would call discrete 6 progressions of. core melt, unique to each train or stream of 7 events.
8 That sound like a fine structure that is going to.
9 be absolutely unmanageable and something that I would 10 contrast to the large LOCA scheme which simplified 11- everything by saying, take a guillotine break, which was the 12 ultimate.
.m
( ) 13 DR. OKRENT: Jesse, let me try to answer, since I v
14 made the comment. What people do in PRAs, and they would do 15 l even more in the IDCOR method, as I understand it, is, they 16 look at the various scenarios that might lead to core melt 17 and they group them into scenarios that have the same 18 general characteristics, starting from the core melt, and 19 they can have some subdivisions of this, and so forth. So 20 that instead of a million or a thousand or whatever it is, 21 they will end up following a number that is probably small 22 compared to 100.
23 MR. EBERSOLE: Okay.
24 (Slide.)
() 25 MR. COFFMAN: As I mentioned earlier, the severe ACE FEDERAL REPORTERS, INC.
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(~'Vbw 1 accident policy does not differentiate among the sources of
[ v I 2 hazards. It includes both external and internal hazards.
1 l- 3 We do not preclude utilities at this time assessing their i
4 plant against external hazards in the initiation of the IPE; 5 however, we think that such hazards considerations are
-6 separable without jeopardizing the results, the individual 7 results, looking at individual hazards to the plant.
8 Both IDCOR and the NRC work has focused on 9 internal hazards, and I need to modify that a little. The 10 IDCOR methodology does include a look for internal floods 11 and fires, and those conventionally tend to be classified as 12 external hazards; however, we think that external hazards (r~) 13 need to be considered, but we think there is more work that 14 needs to be done to determine how external hazards should be 15 considered. But we think it can follow, as far as schedule 16 goes. Possibly, separate looks at the plants for external 17 hazards.
18 MR. MICHELSON: Can I ask a question.
19 I always have a little trouble deciding what is 20 the severe accident, and I am not quite sure. Maybe you 21 can, first of all, tell me what a severe accident is. Then 22 I will have a follow-up question.
23 What is your definition?
24 MR. COFFMAN: Generally, in the generic letter,
(~).
x_-
25 the way we are defining a severe accident is, those ACE FEDERAL REPORTERS, INC.
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- (",,Vbw 1 ~ accidents where there has been substantial core melt. I am
.w 2 'sorry,-not where there has been, but where there could be 3 substantial core melt, and that the' consequences could 4 potentially challenge containment _ performance of fission 5 product retention.
6 MR. MICHELSON: Then the follow-up question. In 7 the case of fire, for instance, we have a certain design 8 basis in Appendix R, from one to.three hours, depending on 9 what part of the plant the_ fire is burning in. A design 10 -basis fire burning in that area, put out at the end of one 11_ hour, would cause an acceptable. consequence, acceptable,-in 12_ the sense'of being able cool the core. A fire of_two hours
() 13 duration-or four hours duration in the same area might lead 14 to core melt, because you did not design barriers, and so 15 forth for long fires.
16 How do you treat that in a' severe accident? Is 17 that a severe accident, first of all, because it burned 18 longer than you thought it was going to burn? And what kind 19 of analysis are you doing in a case like that?
20 MR. COFFMAN: I am going to answer you, not by 21 answering the analyses, but by answering the processw that 22 we are going through to come to what should provide answers 23 to the question. I am asking you to listen to me.
24 MR. MICHELSON: So you are saying the severe
() 25 accident process process will treat such examples.
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/"'Vbw' If MR. COFFMAN: Yes.
%.)
2 MR. MICHELSON: Let me give-you one other example 3 to be sure.I understand the full scope. In the case of pipe 4 inside of containment, we are now going through a little-5 ritual of leak before break, and so forth, which will now 6 prevent the whips and jets that would damage the containment 7 That is the design basis.
8 If, in the unlikely event that we do-get a larger 9 break, one which'is low probability, admittedly, but if we 10 do get it, and it punctures containment, which there's no 11 longer a pipe whip device to prevent it, what do you-do 12 then? Is that a severe accident case that you consider?
MR. EBERSOLE :
.(~s)u 13 In the face of modest core damage 14' MR. MICHELSON: I haven't had any core damage 15 yet, but it is a break that also ruptures the containment, 16 which then inactivates the ECCS outside of containment. You 17 lose the cooling and eventually you get a core melt.
18 DR. SHEWMON: The pipe whipped so hard it went 19 through three feet of concrete?
20 MR. MICHELSON: No, in the case of the BWR.
21 DR. KERR: May I suggest that since the Staff 22 considers that an external event --
23 MR. MICHELSON: Pipe break is not an external l
24 event. In the case of pipe break, for example, you go
() -25 beyond the design basis and postulate, for instance, that if ACE FEDERAL REPORTERS, INC.
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1930 17 17 199 gggVbw 1 you get a bigger rupture --
2 MR. SHERON: One has to look at the PRAs and the 3 like. If that turns out to be a significant sequence that 4 would cause a severe accident, then, youes, it would be 5 considered.
o 6 MR. MICHELSON: So your mechanisms are set up to 7 ask you to look at that to see whether it is going to be 8 discounted on a probablity basis.
9 MR. SHERON: Remember, you are postulating now 10 that the pipe break somehow has enough energy and is enough 11 proximity to puncture the containment, but also, I guess, 12 safety systems fail.
lll 13 MR. MICHELSON: If they come as a direct 14 consequence of the steam now entering the areas where the 15 pumps are, which are just outside of the containment.
16 So those are all probabilities.
17 MR. SHERON: That would be part of the process.
18 MR. MICHELSON: So I would expect to see such an 19 analysis under IDCOR, if there is a credible situation like 20 that.
21 MR. EBERSOLE: Of course, you may not have to 22 rupture the pipe to do that. The containment may be open in 23 the beginning and never did close.
24 MR. MICHELSON: There are whole sets of these lll 25 beyond the design basis scenarios.
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(~'Vbw 1 DR. KERR: I don't think you are going to get v
2 answers to questions this detailed without looking at the 3 material described in the'IDCOR report. We have stacks of 4 it.
5- MR. COFFMAN: That is right.
6 DR. KERR: Please continue.
7 MR. COFFMAN: In giving consideration to external 8 events, we plan to first look at - we are trying to 9 determine the extent to which plants have already been 10 reviewed for external hazards, and then using methods which 1
ar available and those which may come up, trying to assess 11 12 the margins that are'available from past reviews.
13 After having done that, we want to determine if-(f 14 there are features -- if there are plant features that need 15 to be looked at because they are vulnerable to external
. 16 hazards, and then provide guidance on how they should be 17 . looked at.
18 The Stafff is at this point trying to complete
. 19 that aspect of the preparation for an IPE, Preparation for 20 Providing Guidance, from an IPE to an external hazard.
21 That is the process we are in.
22 (Slide.)
23 There is another general item for defining the 24 scope of the IPE, and I think some of the earlier discussion
() 25 in this session was related to this, and that is that there ACE FEDERAL REPORTERS, INC.
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Il 1930 17 17 201 1 are questions that will remain about the completeness of the gggVbw 2 plant analysis which are due largely to uncertainties that 3 are associated with items recalling generic issues, those 4 items being things which lead to early containment failure, 5 such as direct containment heating and under control 6 hydrogen burn.
7 There are some aspects that will not be addressed 8 by the IPE; however, all things considered, we think that 9 there is suf ficient safety benefit to be obtained by 10 proceeding with the IPEs and to make use of the IPEs and .
11 insights gained by a severe accident management scheme, 12 because the safety benefits include the utility involvement lll 13 in gaining a working knowledge of severe accident responses 14 that is planned and for the preparation to prevent and 15 mitigate leading accident sequences.
16 DR. OKRENT: I am in favor, in fact, of some kind 17 of ef fort whereby a utility goes beyond the current 18 emergency procedure guidelines, which stop before core melt 19 but not usually and have at least some knowledge of what may 20 transpire in a severe accident and what might be done, and 21 so on and so forth.
22 It is not clear to me that the only way that they 23 can get a good beginning into that aspect is via the IPE.
24 In fact, I have some concern that many years have gone by lll 25 with most utilities, I will venture, not very sophisticated ACE FEDERAL REPORTERS, INC.
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1 1930.17.17-202 j'ybw. 1- in this area, and the IPE could . stretch out, even if it were A,j 2 approved-under a current' schedule, to take five or six years 3 before the bulk of these are done.
4 I know you show a somewhat shorter schedule, but 5' I am trying to be a little more realistic. I wonder whether 6- the Staff thinks.having utilities having some working 7 knowledge of the severe accidents without necessarily 8 ' interfering with whatever is going to happen in the IPE, 9 whether that is not sufficiently important that it is 10- something to be pursued in its own right.
11 MR. COFFMAN: I would like to try and respond, 12 but I may have to defer here. It seems to me that we think 13 the'IPE as it stands, the'IPE process as it stands'and the
'(])
14 guidance that the Staff is using to initiate the'IPE, is the 15 best way to do it at this time. It may not be perfect, but 16 it is the best way to do it at this time, and that those 17 items which are still uncertain, that we have culled those 18 out, those items which would require further detailed work, 19 although there may be a need to address them now, since 20 there is a large uncertainty, that we are culling those out 21 separately.
22 Should I proceed, or did you want to make a 23 comment? ,
24 DR. OKRENT: I will try again at some other
() 25 management level.
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-1930?l7-17 203-DVbw 1 (Slide.)
Q 2 MR. COFFMAN: We refer to it'as a generic letter,
'3 and we'are rather-loose in that term. Yes, it is a generic
.4 letter. That is the vehicle, but it'is a generic letter 5~ package that is going to the utilities, and the Office of 6 Research is preparing the package to be. issued by NRR to all 7 utilities'. What is intended is that.the package contain 8 what the utilities ~need to plan their approach for an IPE.
9 They contain a generic letter, and they contain guidelines 10 and criteria by plant type, applicable IDCOR IPEM evaluation, 11 and a reference list.
12 I would like to describe these in What I think is t.
() 13 the' appropriate detail.
14 (Slide.)
15 First, looking at the generic letter itself, 16 there will be this request for the systematic examination t
17 that includes not just design but operation maintenance and 18 , emergency procedures.
19 It calls for the utility to identify its leading 20 accident sequences and identify what are the main 21 contributors, which include some of these items. Hardware 22 procedures, both for core damage and containment 23 per formance .
24 In addition, the generic letter asks for a
,( 25 comparison to the applicable guidelines and criteria.
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'1930 17L17 204 1 I am going to describe the guidelinesLand
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2 criteria in a minute, but in essence, it is an aggregation' 3 of-the best insights available on severe accident
'4 vulnerabilities that the Staff and its consultants have put 5' together. It'also calls for that comparison. A generic 6 letter asks for the utility to identify its potential 7 improvements. I think it mentioned that already. It 8 evaluates the potential improvements and to pose what, in
- 9. fact, those improvements should be and also to provide a 10 justification for improvements that had been identified but 11 not recommended.
12 I will come back to the implementation in a f'l s/
13 minute, implementation of the insights.
-14 The generic letter does specify five options that 15 could be used for the systematic examination. These are 16 five general categories of options. There is the IDCOR IPEM 17 is an option. We are also sayign that a Level 2 or a Level-18 3 PRA is another systematic examination. The Level 1 PRA 19 may be supplemented by some alternative containment 20 analysis. There are other simplified PRA methods available, 21 and we do not want to exclude those. Or there may just be
! 22 another systematic examination method available that is not 23 PRA-based.
24 We are encouraging in the generic letter the use
() 25 of existing analyses, if the plant has them. The intent is l /\CE-FEDERAL REPORTERS, INC.
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1930 17 17 205 i
/~]Vbw 1 not to approve methods to the degree that ECCS codes have
%s 2 been codified in their approval but simply to give f
3 sufficient guidance that the utility has a clear conception l
4 of what constitutes a systematic examination of the plant.
5 I would like to describe briefly the guidelines 6 and criteria.
7 (Slide.)
8 These will be attached to the generic lettter.
9 What we mean by guideline is those plant features or 10 operator actions that have been found to be important to 11 risk from previous studies, and the guidelines highlight, 12 but they do not specify potential areas of improvement in 13 plant design and operation.
[v)
14 These are truly, in the sense of guidance, 15 guidelines. The criteria are the standards or attributes.
16 Another word might be the measures to be considered 17 appropriate for assessing the performance of a plant feature 18 or an operator action, and these guidelines and criteria 19 address what the Staff feel are all the past identified 20 features of a plant and have been important to severe 21 accidents. They are listed there. I have nothing to add 22 to.
23 MR. MICHELSON: A comment on the first bullet.
24 Fire is, in varying degrees, an important element of risk.
() 25 If you haven't done a fire PRA, how do you go about deciding ACE FEDERAL REPORTERS, INC.
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g /~'Vbw - l' in your particular plant whether fire is an -important V
2' contributor to risk. Not all plants, by any means, have 3 done fire PRAs, a real fire PRA, not a superficial one.
4 How do you know that it-is even a. contributor 5 and, therefore, something, I guess, you are supposed to look 6 at under severe accident, until you've done a' fire PRA 7 first.
8' Am I thinking wrong, or how does this work?
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'1930 18 18 207 Vbw 1 MR. ROSZTOCZY: Zoltan Rosztoczy, NRC Staff.
2 This is, again, an external event area.
' MR. MICHELSON: You said you were including I
4 external events, though, I thought.
5 MR. ROSZTOCZY: Guidelines should be going out 6 now, which ask them to evaluate internal initiators.
7 Guidance is expected to be issued next year, maybe early 8 next year asking them to do external initiators.
9 MR. MICHELSON: You said something about internal 10 floods already beeing included in this business.
11 MR. ROSZTOCZY: The IDCOR analysis included some 12 of those items that are kind of on the borderline between O 13 internal and externa initiat rs. The statement that Frank 14 was making earlier was that in the generic letter, we are 15 going to mention that we may be asked next year to do the 16 internals. Maybe it would be more comfortable to start it 17 together. We want to start now doing both. For example, 18 doing a PRA, which does both, that would be fully acceptable 19 to us. We would be happy to work with the utility right now 20 to try to see to that, that the way they are doing it will 21 be acceptable.
22 MR. MICHELSON: I assume, internally, that would 23 be acceptable.
24 Not long ago, we discussed A-46 problems, whether
(] 25 or not when a tank falls over, you have to chase the water ACE FEDERAL REPORTERS, INC.
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'/~'Vbw ~ 1 across'the room to see~what it interacts with. When doing a
- ( f 2 severe accident analysis with IDCOR, are'they going to chase 3 the fluids around or steam, or' whatever, to find out what :it-4 'does>
^
5 MR. ROSZTOCZY: My understanding would be that 6 'they have gone that far.
i
=7 ' MR. MICHELSON: They would have to chase the.
8 interactive ef fects, the falling bodies, whatever.
9 MR. ROSZTOCZY: Right.
10 MR. MICHELSON: Okay. Thank you, i 11 MR. COFFMAN: Ther are some notes here on the l 12 bottom of this Vugraph, and at the top of.the next one that
() 13 explain a little about how we develop these guideline 14 criteria.
15 (Slide.)
i 16 DR. SHEWMON: Are you going to go over any of 17 those again? I am concerned about how open-ended the f 18 equipment qualification aspect of it is. We just spent j- 19 several years going. over equipment qualifications. Now the
- 20 question you are raising is, do we have to do it all over 21' again, because that was design basis, not severe accidents?
22 Is is that it?
23 MR. COFFMAN: I think it is best if Dr.
- 24. Rosztoczy, who has a long experience with survivability, can
() 25 answer that.
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/~' -1 MR. ROSZTOCZY: Not exactly, Dr. Shewmon. What
, D .Vbw-2 we.have done in the past is, basically, for the design basis 3 events. The question here is, after an event that 11 ' identifies an important severe accident, is there any 5 equipment that they rely on to handle those events? If they 6 are relying on some, is that properly qualified, so it would 7 do its job? Normally, in the severe accident scenarios, 8 most of the equipment is assumed to fail. That is how you 9 'got to the event. But there are a few that-it would depend 10 on. An example which we normally mention is venting the L11 containment. If you want to vent the containment two days 12 after the accident, and if you tell the operator to initiate 13 venting, when your containment pressure reaches some value,
(])
14 then you are going ot have a device that will measure the 15 containment pressure at that time, two days af ter the 16- accident.
17 It should be designed in such a way that he may 18 rely on it.
19 So this process will identify some diagnostic 20 instrumentation for this purpose and then some equipment 21 that we need to accomplish this.
22 DR. SHEWMON: It would be only that equipment and 23 those instruments; is that right?
24 MR. ROSZTOCZY: Which you rely on to handle these
() 25 important severe accidents.
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1930 18 18 210 f^',Vbw 1 MR. EBERSOLE: Zoltan is. recognition taken that
</
2 pressurization of the containment and failure of it can lead 3 to core melt initiator itself? As a preventive effort, one 4 should pre-vent the containment to avoid severe core damage?
5 MR. ROSZTOCZY: There are some scenarios which 6 would kind of indicate that. We are a little bit skeptical 7 how well can we accomplish this.
8 So if the likelihood of those events could be 9 reduced to a sufficiently low level, it would be a better 10 approach than trying to pre-vent the containment. The idea 11 to consider it is included in the process.
12 MR. EBERSOLE: You suggest that is a minor part,
() 13 but look at the boiler, that is the major problem. When you 14 have AC power failure, you tend toward core melt due to 15 containment failure.
16 MR. ROSZTOCZY: That is right, but even if you 17 look at that case, there are certain contributors to the AC 18 power failure.
19 If you look at one of the contributors, it was 20 maintenance of the batteries. If you can improve the 21 maintenance of the batteries and then reduce the likelihood 22 of this or not happening, that could be more effective way 23 to improve safety. Both ought to be considered.
24 DR. KERR: You recognize I hope that this is part
() 25 of a campaing on Mr. Ebersole's part to demonstrate to the ace-FEDERAL RevoRTERs, INC.
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~
1 rest of us that BWRs are so safe that they don't even need (v]Vbw 2 containment. He is now showing that you save the core by 3 venting it. The next step, obviously, is you don't need a 4 containment.
5 (Laughter.)
6 MR. MICHELSON: I have a question following up on 7 the same thought. In the case of boiling water reactors, 8 there are several lines outside of containment that you 9 worry about rupturing, because if they should rupture, you 10 must isolate the rupture in a very short period of time, or 11 you face the loss of all cooling equipment, and you end up 12 with a core melt through the back door. .
() 13 The HPSI steam line is one example. Are those 14 kind of events covered under IDCOR, by their going in and 15 assuming the valve doesn't close? In the design basis, you 16 assume the valve closes, and you calculate what happened to 17 that 20 seconds it takes to close that, in terms of the 18 effect on the environment. If a valve fails to close, the 19 effect on the environment is quite different, because the f
l 20 reactor continues to blow down through the steam line into l l
21 the basin, where all the ECCS is 1 coated. l 22 Is that kind of scenario covered by IDCOR. l 23 MR. COFFMAN: Yes.
24 MR. MICilELSON: So when I see an IDCOR analysis
() 25 for the Mark 1 BWR, I can read all about how this goes and Ace FEDERAL Runonrnas, INC.
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2 MR. ROSZTOCZY: Frank is in the best position --
3 MR. COFFMAN: Yes, that is covered through the 4 use of detailed questions within the IDCOR methodology, you 5 may want to explore that more with IDCOR.
6 DR. SIESS:
7 MR. MICHELSON: This is when environmental 8 qualification of the equipment becomes important, because 9 the equipment wasn't qualified for that kind of environment.
10 It was qualified for the 22nd valve closure time 11 environment, and it was a quite different answer. In fact, 12 the building isn't necessarily qualified for a long exposure
(~)
v 13 either.
14 MR. EBERSOLE: If you look at that, what valve 15 reliabilities do you use, in view of the fact that the 16 statistical assembly of reliability values --
17 MR. COFFMAN: That reliability is not per se, as 18 they are using modifications to valve unavailability or 19 valve failure rates, by going in and asking the utility to 20 explore all the possible impacts on these valves and 21 adjusting the base probabilities of the failure of those 22 valves.
23 MR. MICHELSON: The probability may be one, of 24 course, depending upon whether the -- you just don't know.
() 25 You would have to look very hard for and how it is adjusted.
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. Q)Vbw .
2 used by a finding that the probability of the original event 3 was low enough, so one doesn't know how the particular event 4 is covered.
5 MR. MICHELSON: Present-day analyses don't show-6 that low probability of pipe ruptures. If you assume the 7 pipe-rupture probability that they are using, you are in a 8_ bad situation, so you have to have pretty good valve 9 reliability, as well, to get down in this lind of a range.
10 MR. COFFMAN: Certainly, the overall action the 11 utility would take would be influenced by the lack of any 12 initiating event, but the methodology is not covered, no
( '13 question, on the individual components.
14 (Slide.)
- 15 This is simply more details about the guidelines i 16 and criteria, primarily on their development.
!- 17 I won't cover this whole Vugraph. It is there 18 for you to read. I simply wanted to amplify on this one 19 point that the Staff and its consultants screened available 20 knowledge from PRAs and PRA-type analyses into severe ,
i 21 accidents, and we reviewed the insights.
22 What is listed here are the screening criteria 23 that we used. These are not specified thresholds to define j 24 vulnerabilities. Rather they are means to assure that when
() 25 we were considering what our possible features that Ace FEDERAL REPORTERS, INC.
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('jVbw 1 influence the outcome of a severe accident that we had a
~s 2 pretty complete list. These are the thresholds we used to 3 screen available PRA information.
4 DR. OKRENT: Excuse me. Is it really obvious 5 that containment failure of any kind that might physically 6 occur after a day is, I guess, innocous, not very important, 7 or whatever is the word that you want to use counter to 8 important?
9 MR. COPFMAN: By itself, I don't think that 10 represents a summary of Staff thinking on the requirements 11 for containment performance. I think the Staff is not 12 interested in any containment failure, regardless of the 13 time, but these were simply what we used to screen the
(~)h w
14 available information.
15 We added to that judgment. We tried to include 16 operator responses and possible operator responses. I have 17 got a whole roomful of containment experts. Maybe there is 18 something else that needs to be said.
19 MR. MICHELSON: Let me ask a follow-up question.
20 Does valve reliability have to be 10 to the minus 21 7 for the containment isolation valves that might be open 22 during normal operation?
23 MR. ROSZTOCZY: Let me just respond to Dr. Okrent 24 first, and then we will come back to that.
() 25 I think the comment is well-taken. We will take ace-FEDERAL REPORTERS, INC.
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1930 18 18 215 I a closer look at whether the second half of that sentence is gggVbw 2 needed.
3 The first step already screens out those events 4 which are very unlikely to happen. Once we are in touch 5 with the relatively likely events, that probably should 6 follow any containment failure.
7 DR. OKRENT: You may or may not have answered the 8 question. I can envisage scenarios, where the containment 9 failed and where the release is really not nice.
10 MR. ROSZTOCZY: It would be our intent that those .
11 would be looked at.
12 MR. PERKINS: Ken Perkins from Brookhaven.
lll 13 I just wanted to add, Brookhaven did a lot of the 14 subcontract on guidelines and criteria and the particular 15 screening criteria of containment failure in less than a day 16 was used to sort out early containment failures. So if it 17 is less than a day, it is called early. I think in 18 NUREG-1150, if you have a severo core accident, it is 19 assumed that you will eventually get to containment failure, 20 one way or the other.
21 So that isn't just saying you ignore it. If it 22 is over a day, it is the same. If less than a day is 23 important, and you want to look at it carefully, you might 24 bypass the trends.
25 MR. MICllELSON: Now the answer on the valvo.
(l)
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(~'ybw 1 Does this reflect the reliability requirements N../
2 for containment isolation valves that are normally open? j 3 MR. SHERON: Yes.
4 MR. MICHELSON: This say one in ten million is 5 the chance of bypass that you are using for the screening 6 criteria.
7 MR. SHERON: I am sorry?
8 MR. MICHELSON: Your screening criteria for 1
9 containment bypass is one chance in ten million.
l 10 DR. SHEWMON: It is more likely than that.
11 MR. MICHELSON: Yes, that is the screening point. !
I 12 Now what level of reliability on the containment isolation valve do you think you need to meet that criteria, i
()_ 13 14 if it is run normally open?
15 Let's just take a hypothetical case. It is 16 always open. You have an accident. Now you have bypassed 17 the containment until the valve is closed.
18 MR. COFFMAN: I don't think we addressed that in 19 the way we used this criterion.
20 We were saying, i f, in fact, it appears that 21 there is a containment bypass likely to have been greater 22 than the threshold value that we would explore from the 23 information available, what were the features in the plant 1
24 that contributed to it being that way. '
s
() 25 MR. MICHELSON: I think you are saying, I l
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("lVbw 1 indirectly, then, that if you have open containment V
2 ventilation during normal operation, you will go in and look 3 carefully at the bypass potential. That is fine.
4 (Slide.)
5 MR. COFFMAN: The generic letter specifies the 6 documentation required by the utility. We are asking for it 7 to be done in two years, because part of the examination 8 process is the documentation of the proceso as it goes 9 along.
10 We are not interested in receiving all that 11 information, so you will see down there as Tier 2 documents, 12 those things which would be retained by the licensees.
(~T 13 It is these things like system notebooks, the
- t. /
14 individual inspection records where they might be looking 15 for interactions as a result of tank ruptures or things like 16 this in calculations.
17 The important thing that we are looking for them 18 to document to the Staff are their insights and their 19 conclusions, their actiors, what actions they plan to take 20 on their potential aceas of improvement, and we would like 21 them to describe their severe accident management scheme, 22 which is the next Vugraph and a topic I would like to spend 23 a little time on.
24 MR. MICifELSON: Before you get to that, one
() 25 general question.
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1930 18 18- 218 In the case of seismic disturbances, severe fVbw.
s) .
.1 2 seismic disturbances, where you look at it under the severe 3 accident policy, how do you treat the nonseismic equipment ;
4 in doing your analysis? Are you looking for failures, and 5 whatever? How do.you treat the nonseismic equipment?
i 6 MR. SHERON: That is external events.
7 MR. MICHELSON: Excuse me, you are right. In 8 about a year, you are going to tell us how to do that.
9 Okay. Sorry.
10 11 12 O 13 14
- r. .
15 l 16 l- 17 1
18 l 19 l 20 I
21 4
22
! 23 24 :
l 25 i
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DAVbw 1 (Slide.)
2 MR. C7FFMAN: The payoff or benefit from doing 3 the IPEM. We feel there needs to be a mechanism to assure 4 it gets into the plant. That is the purpose for this severe 5 accident management scheme, is to assure that these insights 6 are assimilated into the plant's operation and design.
7 The approach is, we are asking the utilities to 8 develop an overall strategy to develop a plan and how they 9 are going to direct that effort to, in fact, strengthen the 10 plant's ability to respond to severe accidents, and that , ,
11 their plan should be based upon the insights they have
() 12 gained from the IPE concerning what are the leading 13 sequences, what are the root causes for these severe 14 accident sequences to be the leading sequences. If there 15 are assumed recover actions within the analysis, then they 16 need to take steps to assure that those recoveries are, in 17 fact, in place at the plant. They will need to define their 18 responsibilities that would be active during a severe i 19 accident. For example, if, in fact, venting was considered 20 a viable alternative for them, they would need to define who 21 makes the decision, who has to be contacted when the 22 decision is made. And those types of responsibilities need <
23 to be part of a severe accident strategy.
() 24 We have in mind some minimum ingredients for 25 their severe accident scheme. They would include -- I guess ACE FEDERAL REPORTERS, INC.
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(~lVbw 1 I have kind of covered that area just a minute ago -- the XJ 2 organizational aspects, the procedures, the training. This 3 would be training, not just picking on the plant, the shift 4 operators, but also at all levels in the organization, there 5 need to be training. Also, the training needs to cover a 6 spectrum of accident outcomes.
7 Then any instrumentation that would be required, 8 and as was mentioned earlier, the survivability needs under 9 those instruments, given that they are relied upon during a 10 severe accident scenario.
11 There may be more than just instruments. There 12 may be other hardware, but we expect that most plant 13 improvements would probably be, most design changes would be
(~s) 14 used for implementation. The severe accident scheme is the 15 heart of a pay-off of an IPE.
16 DR. OKRENT: If I could interrupt for a minute 17 and come back to the question that Mr. Michelson asked,
,48 about how do you treat the nonseismic parts of the plant. I s
19 realize that external events are something you are going to 20 try to provide what I will call a recipe or a group of 71 recipes for later, and that one of things you are 22 considering is, I guess, called the seismic margin, for 23 which I guess that meeting was the target.
24 flaving looked at the report a month or so ago,
() 25 Mr. Michelson's question was not asked and answered in that ACE. FEDERAL REPORTERS, INC.
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1 report. So I-think he may want both to keep it in mind for
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2 yourself and also transmit the questions to Mr. Cuzzi, who 3 is, I think the NRC man following this.
4 Maybe I read the wrong page, or whatever, but my 5 recollection is, they concentrate sort of on success tabs, 6 and they don't face'this particular issue head on in detail.
7 That is, Mr. Michelson's.
8 MR. ROSZTOCZY: I think the point is well-taken.
9 And we should pay attention to it, but there are two 10 efforts. One you referred to and the other is an effort 11 right now undergoing, to try to see how could we fit this 12 into our severe accident evaluation. Even if that method 13 would be available, how would it fit into the overall
.({])
14 picture. And that is more the direction where the question 15 .goes.
16 Dr. Butnitz is doing most of that work for us.
17 Sc we certainly will bring it to his attention. ;
18 DR. OKRENT: He is leading the work for Mr.
19 Cuzzi.
i 20 (Slide.)
21 MR. COFFMAN: The point of the last Vugraph is 22 not so much the schedule per se, but I guess I should have 23 numbered it. It looks like it is the fifth bullet down. We 24 do plan to conduct regional meetings with the facilities and I
l
() 25 then additional meetings in Bethesda to try to continually ACE-FEDERAL REPORTERS, INC, 202-347-3700 Nationwide Coserage 804336-6M6
1930 19 19 222 interact with the utilities as they are conducting their (J
~~ Vbw 1 2 IPE. We would like to maintain the level of interaction 3 with the utilities at a high level, as they are conducting 4 their IPEs, to answer questions that address plant specific 5 aspects that may be out there that we haven't covered.
6 DR. SHEWMON: The original aim of this exercise, 7 as I recall the Commission letter, was to look for outliers 8 or particular risks. And your approach to this has been to 9 say, well, I can evaluate your plan and tell what the most 10 probable events are. But if it is in here, I missed just 11 how we decided to tell how you are going to cope with these 12 and what it would cost.
13 I don't remember seeing anything here that says
( )6 14 when we are going to decide that outlier or how much they 15 have to cost before. It is something we won't do under the 16 backfit rule.- Or just how it is all of this fine effort is 17 going to end up identifying outliers.
18 MR. COFFMAN: The Staff has not set specific 19 thresholds of outliers for vulnerabilities, which, in fact, 20 in the Policy Statement are used interchangeably. The terms 21 outlier and vulnerability. However, the Policy Statement is 22 focused in on not outlier plants but outlier features within 23 a plant.
24 What we have given the utilities -- what we would 25 like to give the utilities in this package is contained in
([ )
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/ TVbw 1 the guidelines and criteria where we spell out the screening V
2 thresholds that we have used, which give an indication of 3 the Staff's thinking, to some degree, but we are not 1
4 predefining " thresholds" for action on the part of the 5 utility. We are leaving that up to them, but we are asking 6 them to identify what they did use.
7 Given the status of the implementation of the 8 safety goal policy, we think this is a viable approach.
9 Maybe Dr. Rosztoczy would like to add.....
10 MR. ROSZTOCZY: As you stated, Dr. Shewmon, yes, 11 the first step in this is to identify potential improvement.
12 Once this is identified, there is a second big step left.
13 What are you going to do about it? How this is
[J~h 14 set up is, they review this list and see which ones do they 15 p.opose to fix and which ones do they think they can live 16 with. That information, then, would be submitted to us as 17 part of the results, saying, here is our list of potential 18 improvements. Here are the ones we are going to fix and 19 here are the ones we don't think we need to, which we can 20 live with for the following reasons.
21 We would receive this from all the plants. We 22 would review them. The ones which came in, and we basically 23 agree with them, they are finished. They would be done. If 24 some plant comes in and indicates that they are really not f')
a 25' doing much in some areas, and we feel they should have done ACE FEDERAL REPORTERS, INC.
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' ('~YVbw - 1 q) 2 cost-benefit analysis and see if they can' afford to do it.
3 DR. SHEWMON: Are there any plans --
4 DR. KERR: Excuse me. May-I pursue this 5 question?
6 DR. SHEWMON: By all means.
7 DR..KERR: Mr. Coffman, you said, I believe, that 8 the policy statement used the term " outliers" to identify 9 sequences and not plants, and this was the approach being 10' taken. I was a little surprised to hear that, because I 11 thought the policy statement concern with plant risk, that 12 in fact,.some plants ~might pose more risk than other plants,
' (~'I 13 and suppose that we want to identify and do something about.
x)
.14 . .If you take the position that outliers refer to sequences, 15 then it seems to me, number one, every plant is going to 16 have some outliers, and I didn't. recognize that that'was the 17 sense of the. policy statement.
18 And second, the approach that I just heard 19 described, it would seem to me that you are likely to get a 20 situatien in which every plant makes some improvement, but 21 you'still have some plants that are a lot worse than others, 22 l because each plant only sort of fixes those things that are 23 worse. And what the policy statement was based on was the 24 assumption that sort of on the average, what we wanted to do
() 25 would be to identify those plants which might have much 14CE FEDERAL REPORTERS, INC.
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(~ ',Vbw 1 greater risk than average.
%J 2 I must be missing something.
3 MR. COFFMAN: The policy statement is built on 4 the conclusion that present plants do not present an undue 5 risk to the total, as an aggregate, do not constitute an 6 undue risk. It says, however, each plant needs to be looked 7 at. So there is the inference that there is the potential 8 for some plants to be further removed from the mean than the 9 others, but it goes on. When it begins to speak of plant 10 vulnerabilities and outliers, the discussion in the policy 11 statement has proceeded to the point that it is talking 12 about what has caused plants or what are the potential
() 13 causes of those plants being outliers, and looking more at 14 not the conclusion of the overall plant, but looking at the 15 conclusion, maybe not even on the sequences, but on the 16 plant features, but it also says past PRAs have been shown 17 to be cost ef fective to change.
18 I guess I was focused in on the terminology of 19 vulnerabilities and outliers. In the policy statement, it 20 is more on plant features, but the inference is that that 21 contributes maybe to some plants.
22 DR. KERR: The difference might be, and again, I 23 am not sure I understand the policy, but it seems to me one 24 might have concluded from the policy statement that some
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.(~lvbw 1 fixing. Some might be bad enough that they would. The V
2 approach that I am hearing described would say to me, as I 3 interpret it, that the . Staff would expect every plant to 4 need some fixing, and it would fix those features that 5 presumably have the highest risk. I am not sure I am 6' interpreting the Staff instructions correctly.
7 Am I' misinterpreting what the Staff is saying?
8- MR. ROSZTOCZY: Let me just go back to the policy 9 ' statement. The policy statement says that based on the 10 information that was available to the Commission at the l
l 11 time, they are not aware of any major generic shortcoming in 12 the current generation of plants. They say it would have to
() 13 be forced in all the plants; however, they said, ever time, 14 when we looked at a plant in some detail, like a. detailed 15 PRA analysis and that analysis always identified some-areas 16 which either needed to be fixed or were prudent to be fixed 17 and almost always these items which were identified were 18 plant-dependent and could not just be transferred from one 19 plant to other.
20 Therefore, the policy statement says each plant 21 ought to be looked at individually, whether they have such a 22 thing, and if they do, then fix it.
23 DR. KERR: But the question is, what is it that 24 you are looking for? Are you simply looking at the biggest
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! 2 somethings which take the plant outside the acceptable 3 population?
! 4 My impression is that you are doing the former.
5 MR. ROSZTOCZY: Originally, the plants were 6 designed for the so-called " design basis accident," and they.
7 were not looked at in any detail for these events. Once the 8' events were identified, we expect the utilities to look at 9 them specifically for these events and arrive either at the 10 conclusion that the plant is sufficiently safs'to 1.. idle all 11 of the identified important events, in which case, they oo 12 not have to do anything, or arrive at the conclusion that 13 there are a number of things which could improve plant 14 performance and, in the owner's judgment, six out of the 25
,15 items need to be fixed, the other 14 do not need to be 16 . fixed.
-17 DR. KERR: So my interpretation wasn't valid.
18 You did not necessarily assume beforehand that every plant 19 will have to do something.
20 MR. ROSZTOCZY: That is correct. We assumed that 21 every plant we identified, which are the controlling events,
-22 and then they address whether there is a need. The 23 conclusion could be that there is no need to do something.
'24 Now we go to the area of, let's say, emergency 25 procedures. One might feel that a review of the current Ace FEDERAL REPORTERS, INC.
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1930 19 19 228 Vbw 1 emergency procedures might need an extension in almost every 2 case, simply because we are at the stage where these events 3 are considered.
l 4 DR. KERR: I am not trying to suggest that every 1
1 5 plant doesn't need to do something, because it may turn out 6 that everyone does, but it wasn't clear to me what your 7 message to the licensees was.
8 DR. SHEWMON: Can we come back to my question 9 now.
10 DR. KERR: Yes, sir.
11 DR. SHEWMON: The other thing is, it seems to me, 12 you are saying, send us a note in 90 days, tell us what you Q 13 are going to do and how you are going to do, and then 14 between 2-1/2 and 3 years now, send us your report. It 15 would seem to me that there could be a learning curve in 16 here. If you could some people to do it earlier and let 17 others learn from it, unless for some reason you don't want 18 them to learn from each other, what they can get away with.
19 MR. ROSZTOCZY: I am not sure if there have been 20 any changes in the generic letter, but the generic letter 21 wording has that in it. We are asking various groups to go 22 on a much faster schedule than this one. Namely, those 23 people who already have PRA and those who have not done 24 anything yet. Those we are urging to go full scale right Q 25 away, because those are the ones we expect to have the most ACE FEDERAL REPORTERS, INC.
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(~~'Vbw 1 difficulty. But there is an encouragement for certain L) 2 groups to go faster.
3 .DR. OKRENT: I am confused. What is the other-4 group?. There are some groups wholhave done a'PRA-or some 5 kind of' study.
6 DR. SHEWMON: There are three'of-them up there 7 that-he-is pointing to.
~
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15 16 17 18 19 20 21 22 23 24
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( ;Vbur 1 DR. OKRENT: Well...
V 2 DR. SHEWMON: What does the priority mean, the j 3 last shall be first? Is that what you are saying?
i 4 MR. COFFMAN: The one with the least shall be 5 first. That is-the intent. The one who has done the least 6 looking for its plant's response to severe accidents should I 7 be first in line because of the urgency of public safety.
8 DR. SHEWMON: There's a couple of ways you can 9 educate people. You can give quizzes every week or hour 10 exams every other week or, like the Europeans do, one set of 11 exams at the end of several years.
o 12 What is your philosophy here with-these people I ') 13 who have the farthest to go? Will you have semester quizzes 14 or interactions?
15 MR. COFFMAN: We plan to have a lot of 16 interactions. The task is divided up between the two 17 offices, Research and NRR, and what ne would like to do is 18 begin in Research and interact rather intensively with a 19 selected group of plants in the first phase as the lead 20 plants in the performance of the IPEs, and we would select 21 plants that we think might be representative.
22 We had in mind ten plants. We would select 23 plants that might be representative of the spectrum of 24 plants so that if in fact generic problems were identified f) v 25 in the process we could maybe short-circuit the learning ACE FEDERAL REPORTERS, INC.
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2 DR. SHEWMON: Okay. Go ahead.
3 MR. COFFMAN: I have completed,.I think.
I 4: DR. KERR: Any further questions of_ Mr. Coffman?
5 (No response.)
6 DR. KERR: Thank you, Mr. Coffman.
7 Mr. Michelson, this is the man who can' answer all 8 your questions.
9- MR. MICdELSON: I am sure he can.
- f. .
10 MR..BUHL: Shall we begin, Mr. Chairman?
11 DR. KERR: Yes, sir.
12- MR. BUHL: My name is Tony Buhl. I am pleased to
() 13 be here'today.
- 14. What I would like to tell you is there is a typo 15 in the title of the organization on the cover sheet. I hope 16 you will forgive that.
17 Also, I won't be using all these slides. I am 18 .only going to be using a subset. I have put them in large 19 type. So I think you will actually be able to see them on 20 the screen.
21 What I would like to do is to frame the IDCOR 22 program, tell you what we have been doing for the last six 23 years, and focus in on the IPE methodology that we have 24 developed, why we have developed it, and then following me ,
i
(][ 25 I have two other people from IDCOR here, Mr. Jim Carter and l
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/ 'lVbur 1 Mr. John Ralston.
'J 2 Mr. Carter will provide you with a very quick 3 outline of what is in the methodology itself.
4 (Slide.)
5 To begin with, in late 1980, in response to the 6 accident at Three Mile Island, the nuclear industry put 7 together a separate group and called it IDCOR, with these 8 particular purposes.
9 The group was to develop a comprehensive, 10 integrated, well-documented and technically sound set of 11 positions on severe accident issues, and many of those 12 issues existed at that time; also, to serve as the U.S.
() 13 industry spokesman with the Nuclear Regulatory Commission on 14 the severe accident issues.
15 In late October 1980, as a matter of fact, the 16 Commission issued in the Federal Register a notice for 17 rulemaking having to do with severe accident issues.
18 (Slide.)
19 The industry established a separate organization, 20 and I won't go through the organization. There is a picture 21 in the chart -- in the handout, at least. But basically 22 that organization was set up as a separate organization that 23 had a policy group comprised of some 70 sponsors of IDCOR.
24 It had a steering group comprised of 12 gentlemen and
() 25 chaired by Mr. Cordell Reed from the inception of the ACE FEDERAL REPORTERS, INC.
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/~";Vbur 1 program. I served as the Program Manager of this program
\j ;
2 since its inception in 1980, and during the course of the j 3 program we had some 23 separate contractors working on the 4 program.
5 DR. MOELLER: What percent of your time?
6 MR. BUHL: My personal time? It varied over the 7 years. Sometimes it was essentially 100 percent. At other 8 times it was much less, depending on what we were doing, but 9 a very large percentage.
10 (Slide.)
11 IDCOR has strong U.S. and international support.
12 It has the support of all the utilities in the United States f')
xi 13 with nuclear power with the exception of four. It has the 14 four reactor vendors, nine architect engineers. Finland, 15 Germany, Japan, Sweden, Taiwan, and also Italy, not shown on 16 this particular chart, have sponsored and are sponsoring the 17 program.
18 (Slide.)
19 IDCOR proceeded in three separate phases. It is 20 important to recognize this to understand how this 21 individual plant evaluation methodology evolved.
22 The first phase of the program, from 1981 through 23 1985, really was a technical program focused on the 24 technical issues, developing new codes, new information, nec
() 25 insights, doing new calculations, and understanding as best ACE FEDERAL REPORTERS, INC.
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[' 1 we could all the open severe accident questions.
v)Vbur.
2 To do this, we selected four, reference plants for 3 these analyses and evaluated those in great detail.
4 In 1985, we changed our mission with the 5 publication of the technical-documents to those shown here.
'6 By 1985, we had reduced the rather large set of 7 questions and technical issues, in working with the Staff,
. 8 down to some 19 technical issues.
9- So our first mission in '85 '86 was to resolve 10 those technical issues as best _ we could with' the Regulatory ill Commission.
12 Second, to develop a methodology which the
() 13 utilities themselves could go out and use to examine their 14 plants and look for these' vulnerabilities that we have been 15 talking about in a systematic and consistent way.
16 We also did some work in that time period on 17- source term and emergency planning technologies and on the 18 issue resolution.
19= In the last couple of years -- and the program is 20 concluding now, I should add, in 1987 -- in the last couple 21 of years we have spent our time testing the methodology on 22 eig55. different plants. We have provided additional 23 emergency planning and support, and we have also supplied 24 information and efforts to the industry on the Chernobyl
'( )- 25 accident.
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(;Nbur 1 'But the focus here today is the methodology v
2 itself and the application of that methodology to eight 3 separate plants by the utilities.
4 (Slide.)
5 During the technical program, very briefly, IDCOR 6 performed an extensive evaluation of the response of LWR 7 nuclear power plants to severe accidents ranging all the way 8 from the initiating events and accident sequences through 9 containment capability, operator resoonse to-severe 10 accidents, all the way down to evaluating the risk 11 perceptions. before IDCOR using the data that we had pre- ,
12 IDCOR and post-IDCOR.
'( ) 13 (Slide.)
14 The technical program comprised 24 major' tasks 15 and resulted in some 53 technical reports which were 16 submitted to the Commission and reviewed by the Commission 17 in numerous meetings.
18 The technical work basically can be thought of in 19 these four blocks. We did a lot of work up front, taking 20 all the PRAs and technical information we had available, 21 evaluating that information both from the equipment and from 22 the human error point of view.
23 We did a lot of work in the second block called 24 core damage prevention, in which we looked at the ability of 25 operators to take the information they have and understand
(]})
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, 1 and manage situations that might arise during severe L.))Vbur l 2 accidents, and also we looked at a large laundry list of I l
3 potential changes and modifications people had recommended j 4 over the years for reducing core melt frequencies.
5 In the lower left block, called containment 6 effectiveness, we recognized that we did not have available 7 to the industry or to anyone, for that matter, an integrated 8 code system which could calculate the response of these 9 reactors to severe accidents.
10 So as a major part of that particular work, we 11 did a lot of work in developing models for the various 12 technical issues and incorporating those models in an
(")
x_/
13 integrated code which we called MAPP.
14 Finally, on the right, bottom, mitigation. We 15 took again a long list of recommendations and suggestions 16 for mitigating features which might be added to the plant, 17 and we evaluated those with the tools we had available and 18 the information we had available to us to look at the actual 19 risk changes that those might bring about.
20 (Slide.)
21 That technical program, as I said, was well-22 documented and submitted to the NRC. This photograph simply 23 shows some of the documentation, the 53 technical reports, 24 the technical summary report. We submitted seven of the I'/') 25 eight individual plant evaluations to the Commission, and we u-ACE FEDERAL REPORTERS, INC.
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)Vbbr~ .1 have' submitted two rather thick methodology reports'to the 2 Commission.
3 In fact, we-have submitted Rev. O, Rev. 1, and 4' Rev. 2, one for the BWR, of course, and one for the PWR. .
5 -(Slide.)
.6 Just a bit of history on the individual plant 7 evaluation methodology.
8 We develope,d the methodology initially in 1985. [
9 We selected eight reference plants to test the applicability 10- of the methodology to the major containment and reactor 21 1 types. We began testing in the late summer of 1985. The-12 methodology was submitted to.the Commission for review and 13 comment in late April of last year.
(}
14 .The NRC gave us comments a number of times, and 15 those comments were incorporated in the production of Rev. I 16 and Rev. 2.
'17 (Slide.)
18 We started this whole process primarily based on
!- 19 - the severe accident policy statement, which came out, and g .20 the quote here from the NRC' severe accident policy statement l
21 is:
22 " Licensees of each operating L 23 reactor will be expected to perform _
i 24 a limited scope accident safety
()
25 analysis designed to discover l 14CE FEDERAL REPORTERS, INC.
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- f~lNbur, 1 instances of particular vulnerability V '
2 to core melt or to unusually poor 3 containment performance."
4 (Slide.)
5 We developed the IPE methodology.
6 According to our understanding of this policy 7 statement, this policy statement did globally state that 8 current plants posed no undue risk but that plant specific 9 studies have identified relatively unique vulnerabilities, 10 that systematic evaluations of all existing plants-should be 11 accomplished in order to discover instances of vulnerability 12 to core melt or unusually poor containment performance.
13 (Slide.)
NJ
- 14. Following the policy statement, about a year 15 later, the-NRC issued the severe accident policy 16 implementation plan, in February of last year, and a central 17 feature of that plan was.the issuance of a generic letter by 18 January of 1987.
19 (Slide.)
20 That particular document from the Commission 21 supported the IDCOR methodology and said that IDCOR has 22 contributed to developing the methodology in some important 23 ways and they developed a detailed risk evaluation method 24 and applied it, and, second, IDCOR has developed and tested
(} 25 a simplified methodology to be used by the utilities for ACE-FEDERAL REPORTERS, INC.
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' 3Vbur. I these individual plant examinations.
v 2 (Slide.)
3 I won't go through here today in detail, but I 4 have included a long laundry list in the handout of many, 5 many interactions we have had with the Staff to deal with 6 the development of the methodology over the last couple of 7 years.
8 I would point out here only that among the things 9 we have done, we conducted a two-day workshop last year for 10 some 30 to 40 members of the Staff in which we walked 11 through the methodology in great detail.
12 We conducted a half-day workshop for the senior 13 management of NRC. I guess all the office directors, as I
( })
( 14 recall, were at that meeting, and a large number of division 15 directors, in which we explained the methodology. We have 16 .
had a number of meetings with the Staff and with senior 17 management as the methodology has evolved through the la various revisions.
19 (Slide.)
20 We have completed from our point of view the 21 methodology. We delivered in a chronology, which I won't go 22 through here, seven of the eight plants. The only pilot 23 plant we have not delivered to the Staff at this point is l
l 24 the Sequoyah plant. 1
() 25 (Slide.)
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(' 1- We are nearing completion of our efforts.. In the A.)Nbur.
2 ~ fall of' last year, we received NRC's comments on the 3 methodology. We delivered the main plants, Calvert Cliffs 4 and Grand Gulf, to the NRC_ last year, and we revised and 5 . submitted the' final revision of the methodology actually 6 .this year.
7 (Slide.)
8 Before Jim goes through the. methodology, I would 9 like to say that we recognize after all we have gone through 10 -- recall that'I said in '85 we had some 19-techn'ical
- 11 : issues. We winnowed those down in the last couple of years
- 12. to a handful of four or five technical . issues. Some'of j][ 13 those are generic issues -- we recognize that further work
-14 ' on these-issues will be required.
-15 .There is still' considerable-uncertainty on 16 several important generic' issues, like hydrogen generation 17 and burn,. direct containment ~ heating and recoolability. We 18 have considered these issues in the methodology and in some
~
19 sense tried to bound these issues.
20 For example, direct containment heating. There i.
21 are a couple of ways one can look at that, and in
- 22. particular, we looked very hard at the geometry and the 23 ability of particular plants to deal with direct containment t
24 heating. Obviously, other things one could do, like venting
() 25 and depressurization.
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(~}Vbur 1 MR. EBERSOLE: .Let me ask a question. One plant
\m/
2 is Sequoyah, right? What are the others?
3 MR. BUHL: Let's go down the list.
4 Do you have the chart on that, Jim?
~
5' I think it is listed in there. I will go down 6- the list.
7 MR. EBERSOLE: Let me just take'Sequoyah.
8 MR. BUHL: There are eight of them.
9 MR. EBERSOLE: Let me just take Sequoyah.
10 Sequoyah has been shut down for a long time.. I don't know 11 when they are going to start it up.
12 If it were to start up today, in the absence of 13 whatever is wrong with it'now, that is going to be fixed, f( )
14 how much would that increase the probability of, say, core 15 melt?
- 16. In short, what 'is the value of what they are 17 doing there today?
18 MR. BUHL: Let me back up.
]
19 What we did with these eight plants was not to 20 try to justify Sequoyah or any of the other eight plants.
21 We were not in the business of doing this for the applicant.
22 What we set up were eight pilot plants. We chose 23 plants. We chose Sequoyah as the ice condenser, and 24 presumably each of these -is going to submit, consistent with 4
(]); 25 the letter, whatever they submit.
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("^).Vbur 1 So we weren't trying to answer the question you A_/ -
2 just asked me. What we were trying to do is to apply this 3 methodology to each of the plant and containment design 4 types and verify that the methodology worked.
5 MR. EBERSOLE: You know what I am trying to get 6 at.
7 What is the value of what is being done in a 8 safety context?
9 MR. BUHL: I think it is extremely valuable.
10 MR. EBERSOLE: But it doesn't Lppear in your 11 analysis?
12 MR. BUHL: You are saying specifically at
(' 13 Sequoyah?
%)
14 I guess I don't see the connection specifically 15 between what they are doing at Sequoyah today necessarily 16 and this.
17 MR. EBERSOLE: This tells me there is no 18 ingredient in your studies to account for what is missing at 19 Sequoyah which causes it to be shut down, which may be a OA
- 20 on equipment?
21 MR. BUHL: Then there would be an ingredient in 22 our study. We believe this methodology is robust. \ at we 23 are not going to do is get in the business of trying to 24 defend or not defend particular licensing issues that are l.
f')
x_/
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'[~NVbur~ 1 particula'r - plants .
J 2 But I disagree with your premise. In fact, this 3- methodology will turn up the issues as they are important to e
4 ' safety. We believe it will.
5 We have tested'it against eight plants. Six of 6 those eight plants had full PRAs. We have had the
) 7 methodology _ applied by the utility people and separate 8 people from those who did-the PRAs, by'the way, and I think 9 the results speak for themselves.
10 DR. OKRENT: If quality at Sequoyah is a real.
-11 issue, I am not aware of anything in:the IPEM method that 12 would h' ave turned it up or that the utility doing the'st'udy
/]) '13 without.have been challenged on this would even ask the 14~ ' question.
15 MR. BUHL: Jim is going to walk through'it. So 16 perhaps we should_ hold that question. But.the methodology 17 does require certain systematic walkdowns, a preparation of
- 18 ~ systems notebooks, so that people are going to go'behind the 19 superficial and understand their plants. I think the 20 methodology will force those who are applying the 21' ' methodology to understand their plants. To the extent that 22- quality on a piece of equipment procedure or what not is in 23 the way, that should be turned up.
24 MR. EBERSOLE: Then you will tell me that it will 25 uncover quality deficiencies in plants other than Sequoyah
(}
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/ ~'Nbur 1 which are still on the line?
V 2 MR. BUHL: It might. I don't know if it will or 3 not. It might.
4 MR. EBERSOLE: I doubt that.
5 DR. OKRENT: This is with two and a half man-6 years total effort? You must be kidding me.
7 MR. MICHELSON: Is performance what you look at 8 when doing a walkdown? Are you looking at performance 9 capabilities? I mean, you are looking at the environmental 10 qualification or the ability and timing?
- 1) i MR. BUHL: Could I ask you to hold the questions?
12 Jim is going to stand up and walk through the methodology.
I~T 13 If you could hold that question, I would be happy to cover
.V 14 it rather than me untangling his presentation piece by 15 piece.
16 Let me just say this. I think this is important.
17 We have gone through two revisions of this methodology. It 18 has been tested. It has been tested on eight plants.
19 I think the important thing about the methodology 20 is that it is a systematic approach. It can be applied, and 21 it can be -- and it would be -- documented consistently by 22 all the utilities for all the plants.
23 Therefore, the results of an IPE can be reviewed 24 in a consistent way.
25 There are certainly other techniques which are
(') ,
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2 presentation, will be allowable in the letter. These techs 3 ~ are also systematic, but they may in fact be difficult in 4 some cases to apply' systematically plant to plant.
5 Therefore, they.will result in a more customized kind of 6 review.
7 I guess our viewpoint today is that the 8 methodology is finished. It has gone through a number of 9 revisions. It has gone through many, many tests by the 10 Staff, many meetings with the Staff. Staff has actually
- 11 visited some of the plant sites and reviewed what is done 12 hands on at the sites.
{). 13 So my view is that even as my last viewgraph 14 points out, there will always be uncertainty. There will 15 always be research in certain areas that will be needed in 16 the future. We have tried to cover these in the best way we
- 17 can.
18 But we believe the methodology is robust and it ,
19 is the best way, in our view, to do systematic evaluation of 20 the plants out there, to uncover outliers if they exist, to 21 use the language of the policy statement, and certainly to 22 define vulnerabilities in the individual plants.
23 What I would like to do to get to some of these 24 questions is to have Jim come up and walk through the guts i
() 25 of the methodology; that is, the how-to, what we do when we J
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'Nbur 1 go through the plant 2 MR. MICHELSON: One general question. You said 3 this methodology had been tested.
4 Does that me,n it has been verified in some kind 5 of fashion or just used?
6 MR. BUHL: It has been verified in the following 7 fashion. Six of the eight plants which we applied the 8 methodology to had already performed full PRAs, and those 9 PRAs were done, as I said, by different groups of people.
10 Nonetheless, we took the results of the methodology after 11 the fact, and we laid that down against what we knew from 12 all sources about the plants, and we found that to be a
/~' 'i . 13 successful test.
n,'
14 So in the sense that we have done that.
15 MR. MICHELSON: Are you saying the PRAs went 16 beyond the design basis?
17 MR. BUHL: Oh, yes.
18 MR. MICHELSON: And that your methodology i 19 compared favorably with the PRA methodology for accidents
, 20 beyond the design basis; is that what you are saying?
21 MR. BUHL: It certainly did.
22 Jim.
23 DR. KERR: Any further questions of Mr. Buhl?
! 24 (No response.)
1
([ ); 25 DR. KERR: Thank you, nir.
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l 11930:21 21 247 Nbur- 1 MR. EBERSOLE: Mr. Carter, I think I just might V b~/
remark that it certainly pleases me to see an old c'olleague 2
.. 3 and coworker from the area.--
4 MR. CARTER: I guess that disqualifies you from 5 asking questions.
6 (Laughter.)
7 MR. EBERSOLE: Therefore,.I think you might have 1
8 a personal interest in.the nature of the~ question I asked.
9 MR. CARTER: All right.
10 (Slide.) .g 11 I am Jim Carter, from IDCOR and IT Corporation.
12 I would like to just give you a brief overview of the IDCOR ,
13 individual plant evaluation methodology.
{} '
'14 (Slide.)
15 I will just quickly walk you through the goals 16 which we have set the IPE methodology to~ accomplish. 'I will.
17 give you a review of the importance of the plant systems 18 evaluation in terms of its evaluations of systems and its 19 conclusion; that is, data operations and emergency. A ,
20 procedures, also the source term. ,
21 I will try to give you a brief overview of 'the 22 importance the system plays in that portion of the 23 methodology, also the interactions between the plant 24 analysis and the source term evaluations.
() 25 (Slide.)
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/~~'3Vb u r ' 1 The goals of the IPE were to form a systematic LJ 2 plant' specific evaluation, as required by the severe 3 accident, policy statement, which suggested that two areas be
.;u - >
J
^
04( evaluated, the plant capability to prevent core damage and
5 its containment performance by evaluating its capability to 3 6 prevent source terms of any size from being released, to 7 provide a systematic systems operation and procedure-
- p
- j. 8 oriented evaluation of a plant; for the front end, and to 9 provido an approach where the' insi'ghts gained from the study 10 can be used very' clearly in the.decisionmaking process.
( -
7 .
. 11 That is, the. methodology is really focused on.
deve' loping insights in a manner which can satisfy 'and
~
12 f) 13 provide for manageqhnt its understanding of how severe h' 14 accidents perform specificalIy for their plant, also to W. .
15' k provide a s'ystematic methodology that can'be reviewed timely 1 . ,
/ <
, 16 in a form that from plant to ,p1 pat allows the Staff to make
~
17 some ability to compare.these readily.
18 DR. MOELLER:- Under your first bullet you have I don't understand the second one, unusually 19"{'twoitems.
20 poor containment performance. =
et21 Does this approach uncover unusually poor 22 contafnment or what?
(.,. 23 MR. CARTER: Yes, sir. We believe the
- jmi t 24 methodology is designed to look for instances where the
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1930 21 21 249
'Nbur 1 perform, generally have less capability than we expected.
('J 2 DR. MOELLER: Thank you.
3 (Slide.)
4 MR. CARTER: This little schematic generally 5 gives you a coupling between the plant systems evaluation 6 and the source term assessment or the containment 7 performance evaluation. It is similar to a PRA. We make 8 use of insights from past PRAs. It is a careful evaluation 9 of operator actions, system availability, sequence 10 definitions, and those all feed into evaluation of
( 11 containment performance.
12 There are very close checks in quality assurance
()
%j 13 to assure that what is assumed in the containment 14 performance evaluation corresponds to what was evaluated and 15 determined available in plant systems evaluation.
16 There is a detailed evaluation that is coupled 17 out of containment isolation. The use of the MAPP code 18 developed in the IDCOR methodology is used very sparingly in 19 the methodology.
20 This is because ILCOR has performed a significant 21 amount of evaluation on sequences and source terms in the 22 past in order to develop a methodology which is efficient.
23 Those have been used extensively.
24 The only use of MAPP in this methodology at
() 25 present would be in developing or going through the ACE FEDERAL REPORTERS, INC.
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1930 21 21 250 methodology process. One may find himself to have a 1
(v}Nbur 1 2 potential outlier or have a potential vulnerability. He can 3 then use MAPP to perform a more detailed assessment of that 4 particular sequence, and also it can be used to check 5 success criteria more closely.
6 (Slide.)
7 The front-end systems methodologies for the BWR 8 and the PWR are very, very similar. There are some slight 9 dif ferences between the two, but they are system oriented.
10 The evaluation includes frontline systems, and it includes 11 support systems, and there is a very detailed study of 12 support systems because we believe that is where from plant
() 13 to plant one would find vulnerabilities, not particularly in 14 the frontline systems.
15 Support systems include power, the service water 16 systems, controls, system air conditioning, system air 17 systems, plant air systems.
18 It is also operationally oriented. There is 19 detailed collection of plant history and plant data where it 20 is available. Some plants may not have operate' 21 sufficiently long that the plant data is useful, but we look 22 for data in terms of trying to define initiators, system
, 23 performance, component performance, and potential problems 24 that may have shown up in maintenance and plant surveillance 25
() procedures.
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()Vbu r 1 Procedurally oriented in assessing plant history, V
2 the operator training at the specific plant, and any 3 additional plant specific procedures that may exist.
4 MR. MICHELSON: Jim, is this procedure similar 5 for use on, say, analyzing a station blackout case with a 6 severe accident?
7 MR. CARTER: Yes, sir. Station blackout is one 8 of the things that we look at.
9 MR. MICHELSON: In the process of doing all of 10 this detailed analysis, you have to have a lot of 11 Information on components.
12 For instance, how do you treat the loss of
_ ([ }; 13 cooling through solid state control cabinets in terms of 14 what kind of response, in terms of unwanted actions, or 15 whatever? How do you start? Where do you get your data 16 base to tell you how solid state control systems respond to 17 elevated temperatures?
18 MR. CARTER: We don't go any further than the 19 environmental qualification for that particular piece of 20 equipment.
21 MR. MICHELSON: If it goes beyond thBL, then what 22 is your assumption?
23 MR. CARTER: That it fails.
24 MR. MICHELSON: Fails in a nice, graceful fashion 25 or fails in an unwanted way or just what?
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'^7Nbur 1 Because this is what severe accidents are all 2 about, going beyond the design basis, going beyond the 3 . design temperature of the equipment, or whatever.
4 MR. CARTER: In the station blackout case, that 5 is beyond design basis in any. case.
6 MR. MICHELSON: Let's just take another case.
7 Say the loss of control room ventilation is the initiating 8 event.
9 In looking at the severe accident potential for 10 that, how do you analyze what happens to the equipment to 11 determine whether you are leading yourself toward a severe 12 accident, or is it even suitable for that kind of analysis?
() 13 MR. CARTER: I think you are asking for an 14 analysis that is really beyond looking at a plant specific 15 vulnerability. First, that would be generic question.
16 MR. MICHELSON: This is clearly plant specific.
17 That is the only way you could analyze it if you have got a 18 particular ventilation scheme, you have a particular heat 19 removal requirement, you have a particular piece of 20 equipment.
21 Now, in that particular type of event, would it 22 give you a severe accident?
23 MR. CARTER: We would assume once it is across 24 the boundaries of its qualification that it fails.
(~)
ss 25 MR. MICHELSON: Fails in a graceful, desirable ACE FEDERAL REPORTERS, INC.
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' ^Nbur 1 fashion?
2 MR. CARTER: Fails in whatever. Fails in a 3 graceful fashion if there is no plant specific data or 4 industry specific data to suggest that particular piece of 5 equipment fails in any other fashion.
6 MR. MICHELSON: This is a very fundamental 7 question because it has to do with how you do the analysis, 8 and that has to do with the answer you get. You can either 9 take the assumption that you lose the function, which is a 10 very simple, straightforward way of analyzing, or you can 11 determine what really happens to the component and what kind 12 of actions causes that.
13 -
It is a difficult move to follow simply because
( ') .
14 the data is often not available.
15 MR. CARTER: The evaluations from all the past 16 PRAs have been looked at.
17 MR. MICHELSON: PRAs don't treat this question.
18 That is the problem. They don't have the data to determine 19 how the equipment responds to adverse environmental 20 conditions, for instance.
21 MR. CARTER: Again, unless equipment 22 qualification testing, and so forth, have discovered that 23 there would be some adverse reaction we do not consider.
24 MR. MICHELSON: Experience has already shown that 25 that is a problem. Real plant experience has shown that
( })
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7.Vbur 1 unusual things happen. Now, you have to look at this in a J
2 more global manner, which is I thought what this process 3 did.
4 DR. KERR: Mr. Michelson, I don't believe --
5 correct me -- that the IDCOR method was ever supposed to be 6 more extensive than a PRA.
7 MR. CARTER: That is correct.
I l 8 MR. MICHELSON: Severe accidents are beyond the I 9 design basis.
I 10 DR. KERR: But so is PRA.
11 MR. MICHELSON: To some extent.
12 DR. KERR: What I am saying is I don't think it T) 13 was intended by its developers that the IDCOR methodology be s_-
14 more extensive than the usual PRA. So if you don't think 15 the PRA is going to treat this problem, I think it is safe 16 to assume that the IDCOR methodology is not going to treat 17 it either.
18 MR. MICHELSON: It is just like flooding 19 equipment. You don't know how equipment responds when it 20 gets wet. Loss of function is a simplistic assumption that 21 could lead to an analytical result. If you are looking 22 really for severe accident outliers, it is a system 23 interaction question.
24 (Slide.)
(')
w/
25 MR. CARTER: To follow up what Dr. Kerr was just
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Nbur 1 saying, the scope of the methodology addresses internal Lj
- 2 events. The methodology is not a PRA. It can be expanded 3 to one, particularly if you decide that is the process you 4 want to follow in the beginning. It requires that you 5 collect more extensive information or the more detailed 6 portions of your system design.
7 It models systems at a high level; that is, a 8 component-level. It includes the critical safety functions 9 and the frontline systems and other systems which could 10 fulfill these functions.
11 The support systems and their dependencies are j 12 explicitly addressed, and as I indicated earlier, that is
(] 13 where we try to spend the majority of the time in our 14 evaluations, in looking at the support dependencies.
15 MR. EBERSOLE: Jim, in connection with my earlier 16 question, I guess I am trying to understand. You take for 17 granted that the OA has been such as to cause the equipment 18 to operate at the specified design reliability without even 19 looking into QA? I I
20 MR. CARTER: To the extent that is a portion of l l
21 the methodology, they are required to develop system i 22 notebooks and detailed information on each system. They 23 would in that process collect qualification information on 24 the equipment.
O; 25 MR. EBERSOLE: What I am saying is you give a L/
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1930 22 22 256 1 blessing to Sequoyah irrespective of whether any OA had been ggfVbur 2 performed on it.
3 MR. CARTER: If the OA is present.
4 MR. EBERSOLE: If it is there to nominal levels 5 of excellence.
6 DR. KERR: Mr. Ebersole, you recognize, I think, 7 that they did not assume equipment doesn't fail. There is 8 some failure rate assumed for the equipment.
9 MR. EBERSOLE: But that is based on some level of 10 QA up front.
11 DR. KERR: That is based on industry experience, 12 whether QA is averaged over this industry?
ggg 13 MR. CARTER: Perhaps I didn't understand your 14 question. There is reliability in the evaluation that is 15 based on industry information, plant specific information.
16 If this plant is worse than others and it is operated for a 17 period of time, then that information should come out in 18 looking at plant specific data.
19 MR. EBERSOLE: But let me just presuppose that 20 there is some plant out there that is just as bad or worse 21 than Sequoyah in the OA context. Whatever the troubles that 22 they have got down there that have caused X million dollars -
23 to have been lost all these years, there is another plant 24 out there that is maybe just as bad off.
lll 25 Would you pick that up? No.
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~'"Nbur 1 MR. CARTER: It depends on bad in which way.
v 2 MR. EBERSOLE: I don't think you are going to go 3 and examine the books. You don't go examine the OA books, 4 by no means.
5 MR. CARTER: That is true. However, the 6 qualification testing information, and so forth, is 7 collected. If that is not available, then that would show 8 up.
9 DR. OKRENT: Could I ask a question?
10 Mr. Buhl said, I think, that the IPEM method was 11 completed. In the documents that the Staff has supplied, in 12 which they provide comments on the IPEM method, they have 13 suggestions and recommendations for things that in their
({ })
14 opinion need to be added or modified, and so forth. It is 15 not clear to me.
16 I will give you just one or two examples. The 17 Staff, as I recall, said that the current IPEM approach for 18 common mode is qualitative rather than using the beta method 19 or some equivalent, and they felt that IPEM therefore needed 20 strengthening in that regard, and there are a variety of 21 other things like this.
22 I am trying to understand, indeed, is IPEM 23 completed and the intent is that it is not to be changed so 24 that it reflects the Staff's recommendations or there is 25 another version of IPEM that they weren't talking about that (v')
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('1Vbur G'
1 has these or, you know, some third or fourth alternative?
2 Can you help me? In general, where do you stand 3 on these different things?
4 MR. CARTER: We have not seen the generic letter, 5 so I can't allude in detail. We have submitted-to them a 6 Rev. 2, and I believe also to the ACRS, that methodology.
7 We considered the methodology final, and perhaps I should 8 defer to the Staff to answer the question, but we don't 9 envision changing the methodology. I think they envision 10 adding or requesting that things beyond the methodology be 11 done.
t 12 DR. OKRENT: So it is a standoff; is that what
(~h 13 you are saying?
LJ 14 I am sure they must have made you aware of these 15 questions during these many meetings you are talking about. ,
1 16 MR. CARTER: Tony, would you like to make a l
17 comment on this? I 18 MR. BUHL: Dr. Okrent, I tried to point out in my 19 presentation that we have submitted Rev. O, Rev. 1, and Rev.
20 2. Both those revisions over the last year and a half have 21 been in direct response to what we have learned in the field 22 in applying these to the plants, more especially to the 23 response and the comments of the Staff.
24 So we have gone through a rather extensive year 25 and a half of review with the Staff, the Staff visiting the
({ )
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v 2 As Mr. Carter said, there are -- we presume, 3 based on the comments we have heard here today from you 4 gentlemen and from the subcommittee, there are additional 5 requests or requirements or comments, however they are 6- stated, from the Staff.
7 We heard at the subcommittee meeting that the 8 Staff was generally satisfied that they did have some 9 additional recommendations. As Jim says, we have not seen 10 those recommendations.
11 It would be inappropriate for us to comment on 12 that which we have not yet seen.
(~'1 13 DR. OKRENT: Let me ask Staff, are the things LJ j 14 that you have for the most part -- let me not say each and i
15 every one that are identified in your discussion -- are 16 these things you have not discussed with the IDCOR people 17 before?
18 MR. COFFMAN: To my knowledge, there is nothing 19 new that we haven't already identified as areas that we 20 thought the methodology could be enhanced.
21 DR. OKRENT: So these are things they have 22 advised you about and you have chosen not to accept, I 23 gather; is that the answer?
24 MR. BUHL: Dr. Okrent, again it is very difficult
/~'s 25 for me to comment on something I have not read. We have
()
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r r' 1 . responded to many, many, many comments by the Staff, and we y}Nbur 2 do expect that some of the augmentations they would have in 3 their letter, which we have not seen, would be there, and we 4 would expect they would be the kind of things we have heard 5 in the meetings.
6 But I just think it is inappropriate for us to 7 try to aecond-guess something we haven't read.
8 DR. OKRENT: Okay.
9 DR. KERR: Gentlemen, let me now point out that 10 we are five minutes over our scheduled time. I don't want 11 to cut.you short.
12 MR. CARTER: I will try to go faster.
(} 13 (Slide.)
14 The way the methodology is applied, one develops 15 system notebooks, and that involves collecting the plant 16 data, the documentation descriptions. Very important and a 17 major part of the methodology is conducting plant walkdowns 18 to ensure that there isn't something unusual about the 19 nystem sitting out there that is not documented.
20 Also, detailed discussions with operators 21 concerning how the systems are used and whether they can be 22 used under the emergency kinds of conditions one would 23 expect to utilize the equipment in.
24 One identifies the initiating events, evaluates 25 and defines system dependencies, develops models for the
(~}
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( 3Vbur 1 support systems, develops models for frontline systems, and v
2 this, as I inilcated earlier, generally goes down to the 3 component levels.
4 And then one quantifies accident sequences 5 through event tree models, and the quantification of 6 frontline systems are done, heavily depending on insights, a 7 myriad of insights that have been developed in a large 8 number of PRAs in the past.
9 MR. MICHELSON: Was information collected on both 10 safety and nonsafety-related equipment or just safety 11 related?
12 MR. CARTER: It is on all equipment.
t)
V 13 (Slide.)
14 In the source term methodology, the methodology 15 is also broken down into a BWR and PWR methodology. They 16 are somewhat different, more different than the front-end 17 methodologies are, although their premise is simplified 18 containment event treess based on development of those 19 things which can significantly affect the source terms 20 released.
21 For Mark I and II containments, there is a 22 dependence between the primary system and the containment 23 that requires using streamlined containment event trees, 24 evaluating those specific dependencies.
25 The key elements in those dependencies are the
( })
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.)"'1Vbur 1 containment failure versus vessel failure, wet well venting,
.V 2 ~ dry well sprays, and debris transport to the suppression-3 pool.
4 DR. OKRENT: Before you run from that, can I ask 5 a question. It is my understanding -- correct me if-I am lt wrong -- that for Mark II IDCOR makes certain assumptions 7 about the distribution of corium when it escapes the vessel, 8 similarly for Mark I; that is, you make a choice of one of 9 several possible behavior patterns.
10 Am I wrong?
11 MR. CARTER: Specifically, one looks very closely 12 at the geometry of the particular containment. In the' Mark
~T 13 II we have several different pedestal areas which are (G
14 distinctly different.
15 Some have downcomers directly under the pedestal.
16 Those would contribute to transporting the debris directly.
17 Some do not have downcomers in that region but have 18 downcomers directly outside.
19 One containment I think has a pedestal that is a 20 sunken pedestal, and one has to treat that differently than 21 the other two.
22 But in each case one looks specifically at the 23 geometry. It is assumed that the material does come out and 24 spray uniformly into the Mark I unless the geometry of maybe
(} 25 some of the older ones which have the deeper cavity would Ace FEDERAL REPORTERS, INC.
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(~TNbur 1 contribute to apportioning a certain amount within the
(/
2 pedestbl and a certain amount outside the pedestal.
3 DR. OKRENT: Well, my understanding, not only 4 from reading what the Staff has written but from trying to 5 follow a little bit what people surmise as they try to 6 analyze containment behavior for the Mark I and Mark II, is 7 that not all expert opinion conforms with the choice, for 8 example, you just mentioned of uniform spreading and 9 solidification, and so forth.
10 Do you allow for the possibility of steam 11 explosions in the Mark II ex-vessel?
12 MR. CARTER: IDCOR's position on the steam
() 13 explosions has been that steam explosions can occur, but in 14 general the amount of debris and the formation of material 15 sizes, and so forth, are insufficient to produce energetic 16 explosions capable of damaging containment.
17 DR. OKRENT: -So if I am a utility, I wouldn't 18 even try to analyze this because I have been given the 19 position?
20 MR. CARTER: In that particular case, yes.
21 DR. OKRENT: Again, it is my understanding here 22 that this is not a thing that the experts universally agree 23 on, and I can give some other examples, obviously, and I am 24 trying to understand --
[)
25 DR. KERR: Do you think there is a position about ACE-FEDERAL REPORTERS, INC.
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,P'7Nbur 1 Mark II behavior on which the experts agree?
T.)
2 HDR. OKRENT: No. .But I am trying to understand
'3- then why one should accept the one chosen here and not some
'4 distribution or' weighting or whatever?
5 MR. CARTER: Perhaps the Staf f --
6 DR. OKRENT: No, it is a question .to IDCOR.
7 MR. BUHL: Let me respond, Dr. Okrent, to that 8 ' question.
9 On steam explosions we did a good bit of work ' up 10 front. I recognize-that, as you said,-there are experts 11 .around the world who have different views, not only on this 12 but probably on most of the other issues as well.
/' ' 13 But on this specific issue, Dr. Speis called
\-)-
l 14 together at the NRC --
15 DR. OKRENT: I am not talking about in-vessel.
16 This working group was in-vessel. On the Mark II I am 17 asking about ex-vessel, possibly damaging -- smaller amounts 18 now can possibly cause damage to some important component, 19 whether it be a downcomer or a wall or something.
20 MR. BUHL: I misunderstood you. I thought you 21 were talking about the ability to damage or rupture 22 containment.
23 MR. CARTER: Let me qualify my answer a little 24 bit.
() 25 We do calculate from the amount of materials and ACE FEDERAL REPORTERS, INC.
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_ _ _ _ . _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _. ]
7 L-
~1930 22 22 265
- ~*NburL 1 the heat loss rapidly what the pressure increase is.'
- (v .
2 DR. OKRENT: That is different than a steam n
3- explosion. What I am trying to get at is it is not obvious 4 to me, especially in the containment behavior area -- and I 5 'will for the moment reflect only on the PWRs, since I 6- haven't looked that hard at what is on the BWRs -- that the 7 paths in effect. handed by IDCOR to the utilities are -
8 necessarily the leading candidates, let alone the only ones, 9 for some of these accidents.
10 There fore , I don't know what kind of assessment 11 we will be getting of containment.
12- I will just leave it at that. I don't know that 13 you can answer. I am lef t with this difficulty.
(])
14 MR. CARTER: First of all, it would not be a 15 plant-to-plant dif ference. Most of the features that you 16 are describing and are concerned about would be generic.
17 DR. OKRENT: I don't know that that is the case.
18 There may be different layouts of downcomers, or whatever, 19 that affect it. You may be right, but it is not obvious 20 MR. CARTER: Having been involved in the BWR 21 containment programs for years, I don't believe that you 22 would find significant differences that would contribute 23 from one plant to another being substantially different.
24 DR. OKRENT: So I should worry about steam 25 explosions for all the Mark II's?
. ( )'
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i 1930 22 22 266
! (~Nb u r 1 MR. CARTER: If you are going to worry about them
> %J 2 at all. Our position is that they are not sufficiently 3 energetic to cause you damage.
4 MR. MICHELSON: Are there any downcomers directly 5 under the vessel on Mark II's?
6 MR. CARTER: Those plants have?
7 MR. MICHELSON: You don't consider that kind of a 8 direct target for the corium coming out of the vessel and if 9 you lose the downcomer you bypass the process and proceed to 10 pressurize the containment?
11 MR. CARTER: There is a specific evaluation in 12 the methodology for that case.
(} 13 MR. EBERSOLE: Let me ask you a question about 14 the Mark I's. You know there was a big hassle about the SRV 15 and the chipping effects which led to all the T quenchers, 16 and so forth, and keep the donut from jumping up and down on 17 the floor.
18 I can't remember whether with the large 19 downcomers one looks at the dynamic oscillatory condensation 20 phenomenon.
21 MR. CARTER: Yes.
22 MR. EBERSOLE: Certainly, I don't think it was 23 through direct experimentation that they confirmed you 24 didn't have severe dynamic; it was merely analytical. You l 25 just can't do those big things?
( })
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'TNbur 1 MR. CARTER: We did do a full-scale section of a G'
2 Mark I containment.
3 MR. EBERSOLE: When you said "section," I 4 remember of course the Humboldt vein test which was supposed 5 to have a full-scale section, but it was a pie-shaped piece.
6 It never entered the dynamic suppression heat sink.
7 MR. CARTER: This was a 16-section, full diameter 8 Mark I containment with the end pieces designed to give the 9 structural response to the remainder of containment.
10 MR. EBERSOLE: So you are telling me there has 11 been some model experimentation of the big downcomers?
12 MR. CARTER: That is correct.
13 DR. KERR: Mr. Carter, how much longer is your (v~)
14 presentation likely to take?
15 MR. CARTER: I have about three or four more 16 slides. I can move rapidly through them.
17 DR. OKRENT: I won't ask any more.
18 (Slide.)
19 MR. CARTER: The PWR source term methodology is 20 similar for the large dry containments to the BWR. The 21 IDCOR evaluation of ice condensers and its evaluation of the 22 similar ice condensers, I have concluded that they are 23 essentially the same as Sequoyah and therefore no specific 24 methodology is provided.
~
25 For large dry containments there is pretty much (d'
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.1930:23 23 268 1 independence between the system and previous responses.
V('"?Nbur 2 Therefore,- the 'MAPP analysis reported 3 characteristics of it.
4 - Our time for debris dryout in containment, the 5 time of containment failure, aerosol generation rates, 6 . aerosol settling rates and the release of nonvolatiles, 7 including tellurium.
8 (Slide.)
9 Streamlined trees -focus on the major mechanisms 10 that can retain fission products in the containment, allow a
~
11 structured method of sorting . the source terms into bins on' a 12 sequence specific basis, and we believe they are sufficient
(} 13 for identifying outlier conditions.
14 (Slide.)
15 I will give you a -picture of what these 16 simplified trees look like.
17 This first tree is for the large dry PWR ,
18 containment.
19 If you follow the questions, it asks -- the major 20 features:
21 Is the containment bypassed?
22 Although each of these-nodes look very simple, an 23 extreme detailed analysis must go behind the response to 24 each of these questions.
() 25 Is the containment isolated?
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I 1930 23 23 269
('"lNbur 1 Two very important things for large dry U/
2 containment.
3 Then when you get beyond that point, it becomes 4 very simple.
5 Is the debris covered by water and can you keep 6 it covered by water by containment heat removal?
7 If you have containment heat removal, the source 8 terms are going to be small. If you don't, eventually the 9 containment can fail once the debris dries out.
10 So we got through a very detailed evaluation to 11 address each of these questions.
12 MR. MICHELSON: Just a brief question.
()
v 13 In the case of where the containment is 14 bypassed -- for instance, a HPSI line break outside of 15 containment -- does your modeling now show how the eventual 16 fission product releases, and so forth, come back through 17 that open pipe?
18 MR. CARTER: Yes. In the case of containment 19 bypass, the methodology takes you into the section of the 20 analysis which would suggest doing a detailed MAPP 21 evaluation or source term evaluation of that sequence.
22 MR. MICHELSON: Of that pa'rticular route then it 23 takes an ad hoc analysis of some sort; is that it?
24 MR. CARTER: It will look at the various systems
() 25 and where the systems are likely to f ail outside containment ACE FEDERAL REPORTERS, INC.
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1930 23 23 270 t'~^Nbur 1 and evaluate the source terms for those spots.
V 2 MR. MICHELSON: But the source term is looking 3 through the pipe back at the core?
4 MR. CARTER: That is true.
5 MR. MICHELSON: The core is melting because it 6 lost its cooling?
7 MR. CARTER: That analysis will couple the core 8 melt and the release of the fission products.
9 When you don't have those situations and you have 10 the debris covered, then from our previous analysis we can 11 pretty much assign a source term to it, an approximate l 12 source term, albeit a conservative source term.
?
() 13 MR. MICHELSON: The transport mechanisms are 14 altogether different because it is steaming severely in the 15 core and you can carry all this release right on out the 16 pipe?
17 MR. CARTER: And MAPP is an integrated analysis 18 code that couples the thermal hydraulics with the fission 19 product transport mechanisms.
20 (Slide.)
21 DR. KERR: We are willing to stipuls*.e to that 22 slide.
23 MR. CARTER: Very good.
24 In that case you have brought me to the end of my 1
() 25 presentation. l l
ACE FEDERAL RnpoRTERs, INC.
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1930 23 23 271 t'~'?Nbur l' DR. KERR: Further questions of Mr. Carter?
V-2 (No response.)
3 DR. KERR: Thank.you very much.
4 MR. BUHL: May I make a short comment?
5 DR. KERR: As-long as it is short.
61 MR. BUHL: What I would like to do is maybe make 7 a little.more clear the question that'Dr. Okrent asked.
8 DR. KERR: Is this a question or an answer?
9 MR. BUHL: The answer.
10 Last week in my presentation I had basically the 11 same line of questioning about the difference between what 12 is in the package and what is in the IDCOR methodology on
'(-
/
) 13 page 185 of the transcript.
~
14 I said I heven't seen the generic letter, so I 15 can't cover it. But !mportant thing on page 185 and 186 16 is what Dr. Spels, who is not here today, said, and I would 17 like to quote Dr. Speis from page 185 and 186, and I quotes 18 "Let me say, first of all 19 about the package, that the 20 package has been sent to the 21 ACRS along with the draf t letter 22 and our evaluation of it, 23 information that has to be 24 provided to the Commission and
() 25 the CRGR. We have discussed ACE-FEDERAL REPORTERS, INC.
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1930 23 23 272 2,C?Nbur - I with these gentlemen these V
2 issues, including the things
_3 that we.are planning to include 4 in the generic letter. Having 5 said that, let me make sure that 6 we need to clarify'these things 7 that maybe were alluded to.
8 David Ward said he didn't see 9 any emotional minuses or pluses 10 on our side when we were listening 11 to Bob Henry. What I meant by 12 that, I think the differences between us and IDCOR are minor.
] 13 They are not large. We said in 14 15 the generic letter that we do 16 approve this methodology as.ona 17 of the methodologies to be 18 utilized."
19 And, finally, on page 187, again still quoting l 20 Dr. Speis:
21- "Again, the methodology we 22 think is adequate to do what has l
i 23 to be done. The point is we 24 just have to make sure that the 25 utilities can use this methodology ACE-FEDERAL REPORTERS, INC.
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/7Nbu r 1 for managing their operation in a
, (f 2 ~ continuous fashion in case they are 3 doing some calculations at the 4 beginning and then forgetting about 5 them. So I think that these are 6 minor things, as far as I can see.
7 Maybe Tony would like to respond 8 to that. I just wanted to say 9 this tx) make sure to erase the 10 impression that there are radical 11 differences."
12 End quote.
13 DR. OKRENT: Thank you. I did read the
-( ).
14 transcript, so I-know about that.
15 I am still quite unsettled.
- 16. DR. KERR: The conversation was more about the 17 front-end part than the containment event tree unless I am 18 mistaken.
I Are there further comments or questions?
19 20 (No response.)
l
, 21 DR. KERR: Again, thank all of you who 22 participated.
f 23 I think you are aware of the fact that there is a
- 24 draft letter coming out on this, which you have. I would 25 hope that you get a chance to read it before tomorrow.
l(}
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1930 23 23 274 l
l('{;Vbur 1 (Whereupon, at 4:40 p.m., the committee went into
[v I
2 unrecorded session.)
3 4
I 5
6 7
8 9
10 -
11 12
,Q
\s 13 14 15 16 17 18 19 20 21 22 23 24 25 1
ACE FEDERAL REPORTERS, INC.
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CERTIFICATE OF OFFICIAL REPORTER b
This is to certify that the attached proceedings before the UNITED STATES NUCLEAR _ REGULATORY COMMISSION in the matter of:
NAME OF PROCEEDING: ADVISORY CObu4ITTEE ON REACTOR SAFEGUARDS 326TH GENERAL MEETING DOCKET NO.:
PLACE: WASHINGTON, D. C.
DATE: FRIDAY, JUNE 5, 1987 4
were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission.
t (sigt (TYPED) k v DAVID L. IlOFFMAN Official Reporter ACE-FEDERAL REPORTERS, INC.
Reporter's Affiliation A
- V
9' O
OPERATING REACT 0P EVENTS BRIEFIING FOR THE ACRS JUNE 5, 1987 PLANTS EVENT- PRESENTER FT, CALHOUN 1 MANAGEMENT CONTPOL OF PLANT R LOBEL CATAWBA 2 ACTIVITIES OYSTER CREEK 1 OCONEE 1, 2 a 3 FOULING OF LOW PRESSURE H. PASTIS SERVICE WATER, LOW PRESSURE INJECTION 8 REACTOR BUILDING COOLING UNITS WNP-2 WATER IN STEAMLINE C. SCHULTEN
(])
DIABLO CANYON 2 LOSS OF RESIDUAL HEAT W. LYON REMOVAL 8 RCS THERMAL TRANSIENT 6
O
a
$ MANAGEMENT CONTROL OF PLANT ACTIVITIES O PROBLEM LAPSES IN MANAGEMENT OF PLANT ACTIVITIES CAUSE REPEATED lINANTICIPATED EVENTS, EXAPPLES FORT CALHOUN LOSS OF ALL AC POWER, MAINTENANCE ON BOTH OFFSITE AND ONSITE AC ELECTRICAL POPER SYSTEMS, CATAWBA UNIT 2 LOAD REJECTION TEST WITH tlNIDENTIFIED LEAK, LICENSEE PERFORMED TEST WHILE IN TECH SPEC ACTION STATEPENT, OYSTER CREEK - DEGRADED CONTAINMENT INTEGRITY, COGNITIVE ERROR BY SR0 AND STA INADEQUATE PROCEDURES INADE0VATE SAFETY REVIEW SIGNIFICANCE
(]) PLANT MADE MORE VULNERABLE TO UNANTICIPATED EVENTS, FOLLOWUP CONTINUING NRR/ REGIONAL EFFORTS T0 IMPPOVE PERFORMANCE, i
l
\
t L_______________________.________________ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
o OCONEE 1, ? AND 3 - UPDATE ON FOULING OF LnW PPFSSUPE SEPVICE
([} WATER, 1.0W PRESSURE INJECTinN AND RFACTOR BUILDING C00 LING UNITS PARCH 31, 1987 - (H, PASTIS, NRR)
PROBLEM:
REDUCED HEAT TRANSFER CAPABILITY OF THE LOW PRESSUPE INJECTION (LPI) AND PEACTnP BUILDING COOLING UNIT (RBCU) HEAT EXCHANGERS LIMITS REACT 0P OPERATING POWER CAUSE: LAKE SEDIMENT DEPOSITED IN PEAT EXCHAf!GERS SIGNIFICANCE:
SAFETY ECUIPFFNT INCAPABLE OF PERF0PFING THE DESIGN HEAT PEJECTION SAFETY FUNCTION DISCUSSION:
THE L0k' PRESSURE SERVICE WATEP SYSTEM TAKES PAW LAVE PATER TO COOL THE LPI AND PBCU HEAT EXCilANGERS LICENSEE ANALYZED THE TEST DATA AND CORPELATED IT TO EMERGENCY CONDITIONS I *
($) THE ANALYSIS SHOWED THAT UNDER LOCA CONDITIONS, THE HEAT EXCHANGEPS P0ULD NnT PERFORM AT DESIGN RATING llDDATE:
ON APRIL '0, 3987, NRR ISSUED A CONF!RMATORv nRDER VHTCH
- FEDUIRED THAT 'l:F PEAT FyrHAk'GFDS PF CLEAFFP M!D TESTED PF/CTnR OPFP/Tirr IT tr"fr PnPER LEVELS WITHIN THE HFAT TPM'EFEP Cf P/PILITY OF THE HEAT EXCHAGEOS
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CAUSE' OPERATOR ERROR AND PROCEDURAL DEFICIENCIES i
SIGNIFICANCE POTENTIAL WATERHAMMER SCENARIO AT HIGH PRESSURE (> 500 PSIG)
SEQUENCE OF EVENTS FAILED FUSE CAUSES MAX FEEDWATER DEMAND; FW PI'MPS TRIP ON LOW .
SUCTION PRESSURE, ANTICIPATORY MANUAL SCRAM; RV LEVEL 2 IMITIATES HPCS, RCIC, ATWS RECIRCULATION PUMP TRIP, AND NSSS VALVE GROUPS 1-VII ISOLATION.
HPCS MANUALLY ISOLATED PRIOR TO LEVEL 8; RCIC AllT0MATICALLY ISOLATES AT LEVEL 8.
OPERATOP #1 IMPROPERLY LINES UP FW/ CONDENSATE SYSTEM; OPERATOR
() #2 OPENS RELIEF VALVES DROPPING PRESSURE FROM 1000 PSIG TO APPROX. 600 PSIG; OPERATOP #3 BEGINS DRYWELL COOLING REC 0VERY PROCEDURES. EQUIPMENT OPERATOR THOUGHT THAT PCIC TRIPPED ON MECilANICAL OVERSPEED, INFORMS CONTROL ROOM.
INVENTORY LEVELS OFF AT OR BELOW MSL, 108". PRESSURE CLIMBS TO APPR0X. 880 PSIG.
OPERATOR OPENS 2 RELIEF VALVES. INVENTORY PASSES THRU RVS CAUSING LEVEL TO DROP TO +75 INCHES, AND PRESSURE TO DPOP TO 650 PSIG AT WHICH POINT BOTH B0OSTER PUMPS ADD INVENTORY.
l VESSEL OVERFILLED INTO MSL (+150 INCHES), P IS APPR0X 650 PSIG.
R B0OSTER PUMPS MANUALLY TRIPPED. DRYWELL COOLING RECOVERY PROCEDURES COMPLETE.
OPERATOR OPENS REllEF VALVE AT 850 PSIG. INVENTORY PASSES THRU RVS CAUSING LEVEL TO DROP.
OPEN OUTBOARD MSIV TO ESTABLISH PRESSURE CONTROL USING PYPASS ,
i VALVES. MSIV EQUAll2AT10N PROCESS CONTRIBUTES TO STEADY PRESSURE DECAY Pp = 750 PSIG Lp * +55 INCHES. -
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([) OPERATORS RESTART 1 B0OSTER PUMP, BOOSTER PUMP INJECTS (Pp = 650 PSIG Lp = +30 INCHES) WITH BYPASS VALVES CONTROLLING PRESSURE TO 610 PSIG.
OPERATOR CLOSES OPEN llP HEATER BLOCK VALVES 112A, B.
VESSEL OVERFILLS INTO MSL, OPERATORS TRIP B00 STER PUMP.
FOLLOWUP REGION V EVALUATING LICENSEE PERFORMANCE AND CONSEQUENCES (STEAMLINE LOADING) 0F INCIDENT LICENSEE TO IMPROVE OPERATOR TRAINING FOR LOW LEVEL AND OVERFILL TRANSIENTS; IMPROVE PROCEDURES INCLUDING ADMINISTRATIVE CONTROL.
EVENT IS BEYOND USI A-47.
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s 4
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1 LESSONS LEARNED i
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! DIABLO CANYON UNIT 2 1
l
- i LOSS OF RHR ON t
APRIL 10, 1987 i
6/5/87
OVERVIEW PLANT TYPE: WESTINGHOUSE FOUR LOOP, 3411 MW(T)
TIME SINCE FULL POWER: 7 DAYS CONDITION: RCS AT MID-LOOP, CONTAINMENT EQUIPMENT HATCH
- REMOVED, OTHER PENETRATIONS OPEN, RHR IN OPERAT;ON, REACTOR VESSEL HEAD IN PLACE INITIATOR: LOSS OF RCS INVENTORY DUE TO FAILURE TO ISOLATE RCP SEAL RETURN LINE PRIOR TO TEST IMPACT: LOSS OF RHR FOR 85 MINUTES l
w w
OVERVIEW PLANT TYPE: WESTINGHOUSE FOUR LOOP, 3411 MW(T)
TIME SINCE FULL POWER: 7 DAYS COND! TION: RCS AT MID-LOOP, CONTAINMENT EQUIPMENT HATCH REMOVED, OTHER PENETRATIONS OPEN, RHR IN OPERATION, REACTOR VESSEL HEAD IN PLACE INITIATOR: LOSS OF RCS INVENTORY DUE TO FAILURE TO ISOLATE RCP SEAL RETURN LINE PRIOR TO TEST IMPACT: LOSS OF RHR FOR 85 MINUTES w w w
l' CONCLUSIONS REGARDING DIABLO CANYON EVENT PLANT NEVER IN ACTUAL DANGER, EVENT COULD HAVE CONTINUED FOR OVER A DAY WITH NO CORE DAMAGE AND NO OPERATOR ACTIONS "NO" RADIOACTIVE MATERIAL RELEASE BUT MANY LESSONS LEARNED WITH GENERIC IMPLICATIONS l
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RELATED ACTIVITIES EARLIER AEOD EVALUATIONS INFORMATION NOTICES 50.54(f)' LEI I ER CRGR MEElING JUNE 1O AIT REPORT 50-323/87-18 (N U REG 1269)
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NRC ALDIT OF MIfERALOGY/KTROLOGY PROGRidi AT LOS ALN4)S f4TIOiML LADORATORY o "MIlil"-AtoIT o TENiiGEERS o C0ftECTIONS BEMEii COIMOL SYSTBi FAILURES AIO TECHNICAL PROGR/#S 9
9 O O O
W 9
PURPOSE OF QA REVIEW PLAN 0 GUIDANCE FOR DOE QA PROGRAM 0 NRC EVALUATION OF DOE QA PROGRAM 0 SITE CHARACTERIZATION PHASE i
1 0
- # G e
G 1984 QA REVIEW PLAN 0 GAME PLAN - BRIEF
- 2. ON-SITE REVIEWS
- 3. MEETINGS WITH DOE 0 18 CRITERIA -
- 1. BASED ON REACTOR SRP
- 2. TERMIN0 LOGY - REACTOR VS. REPOSITORY
- 3. SCIENTIFIC INVESTIGATIONS O O O
1987 REVISION 0 WHY
- 1. FORD STUDY
- 2. 3 YEARS USE 0 OBJECTIVES
- 1. IDENTIFY IMPROVEMENTS / CLARIFICATIONS (A) FORD STUDY (B) COMMENTS FROM DOE (C) NQA-1
- 2. INCORPORATE IMPROVEMENTS / CLARIFICATIONS (A) VALUE <
(B) IMPACT O O O
0 EXPECTED CHANGES
- 1. GAME PLAN - MORE DETAILED (A) REGULATORY REQUIREMENTS (B) INFORMATION NEEDS (C) PLANS
- 2. 18 CRITERIA (A) ELABORATE ON QA FOR SCIENTIFIC INVESTIGATIONS (B) END0RSE NQA-1 0 SCHEDULE
- 1. Draft - Sumer 1987 i
I J
i O O O P
)'
L)
LICENSE RENEWAL POLICY DEVELOPMENT:
HRC ACTIVITIES AND PLANS AND RELATED INDUSTRY ACTIVITIES PRESENTED TO THE ADVISORY COMMITTEE ON REACTOR SAFEGUARDS q
v JUNE 5, 1987 DONALD P. CLEARY, SENIOR TASK MANAGER REACTOR AND PLANT SAFETY ISSUES BRANCH DIVISION OF REACTOR AND PLANT SYSTEMS OFFICE OF NUCLEAR REGULATORY RESEARCH U.S. NUCLEAR REGULATORY COMMISSION i
O
- v
'0 D
TOPICS NEED TO DEVELOP A LICENSE RENEWAL POLICY STAFF ACTIVITIES,-PLANS, AND SCHEDULES INDUSTRY ACTIVITIES POLICY AND TECHNICAL ISSUES O
O
1 O
DEFINITIONS l LICENSE RENEWAL - THE ISSUANCE OF A NEW LICENSE TO OPERATE BEYOND THE 40 YEAR TERM OF AN EXISTING LICENSE.
LICENSE EXTEf4SION - EXTENDING THE TERMINATION DATE OF All
, OPERATING LICENSE TO ALLOW 40 YEARS STARTING WITH THE INITIAL DATE OF OPERATION.
i LIFE EXTENSION OR PLANT LIFE EXTENSI0ri-(PLEX) - AN 4
O INDUSTRY Tern iNv0tviNG EXTENSION OF THe ECON 0nIC tiFe OF A PLANT AS WELL AS LICENSE RENEWAL.
T a
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L I
1' O
r i...-_-- . . . - . - _ - _._ , - . _ . . - _ _ . . - - _ _ _ - _ _ . . - . . , . , . _ . . . . . - _ .
STAFF SCHEDULE MAJOR MILESTONES O
SEND INFORMATION PAPER TO COMMISSION DISCUSSING JUN 1987 LICENSE. RENEWAL' ISSUE, STAFF APPROACH TO POLICY AND REGULATORY DEVELOPMENT, SCHEDULES, AND ANALYSIS OF PUBLIC COMMENTS ON LICENSE RENEWAL FEDERAL REGISTER NOTICE IDENTIFY REGULATORY POLICY ISSUES JUL 198/
IDENTIFY POLICY OPTIONS FOR RELICENSING AND FALL 1987 MEET WITH COMMISSION TO REQUEST APPROVAL TO ISSUE POLICY OPTIONS FOR PUBLIC COMMENT EVALUATE REGULATORY OPTIONS OCT 1987 -
AUG 1988 1(]) PROPOSE A LICENSE RENEWAL POLICY TO SEP 1988 COMMISSION FOR PUBLIC COMMENT CONSIDER PUBLIC COMMENTS, INTERNAL REVIEW OCT 1988 -
AND REFINEMENT OF PROPOSED POLICY, START AUG 1989 DEVELOPMENT OF PROPOSED REGULATIONS TO IMPLEMENT POLICY INITIATE EFFORTS TO DEVELOP REG. GUIDES AND SEP 1989 OTHER GUIDANCE DOCUMENTS TO IMPLEMENT LICENSE RENEWAL REGULATIONS PUBLISH FINAL LICENSE RENEWAL POLICY AND ISSUE SEP 1989 PROPOSED REGULATIONS FOR PUBLIC COMMENT I
PUBLISH FINAL REGULATIONS 1992 COMPLETE ISSUANCE OF REG. GUIDES AND STANDARD 1995
({} ,
REVIEW PLANS W. , .-rn- , v , , n - - - . - - - . . - . - - , , - - - , , , . - - e e,-g -- - ,=-- - - - - ve . , .,n--,--m , ~-e r
\ -
TIMING CONSIDERATIONS IN ORDER TO PLAN FOR FURTHER POWER NEEDS MANY UTILITIES WILL NEED REASONABLE ASSURAf1CE OF ABILITY TO OBTAIN LICENSE RENEWAL AT LEAST 10 YEARS PRIOR TO EXPIRATION OF AN ORIGINAL LICENSE.
SOME UTILITIES WILL WANT FLEXIBILITY IN TIMING OF APPLICATION AND TERM 0F LICEllSE.
SCHEDULE OF POTENTIAL APPLICATIONS NUMBER OF PLANTS O -70 U
65 .
60--
55-50-License Expires 45-Within 12 Years 40< .
35i \
30-
'i 25i 20-15] . License Expires In 12 Years 10-'
O O i .
s liilI.
i fl.
trllI A8 P9 90 91 92 93 94 95 96 97 98 99 00 01 02 03 04 05 06 07 09 09 10 13 12 13 YEAR
. i..
(s ORGANIZATION, RESPONSIBILITIES, AND C0 ORDINATION FOR LICENSE RENEWAL PROGRAM CONTRACTUAL RES ASSISTANCE . (DRPS/RPSB) ACRS MITRE LEAD RESPONSIBILITY To REVIEWS 8 OTHERS DEVELOP POLICY a REGULATIONS COMMENTS 8 INCORPORATE AGING RESEARCH RESULTS n
INDUSTRY RES/DE OGC 8 PUBLIC DIRECTS AGING RESEARCH REVIEWS LEGAL INPUT VIA COMMENTS IDENTIFIES TECHNICAL ASPECTS OF LICENSE ON DRAFT POLICY &
O- ISSUES ASSOCIATED WITH RENEWAL (E.G. NEPA) DRAFT REGULATIONS AGING JL L'
INDUSTRY, EPRI DOE TIRGALEX TECHNICAL RESEARCH TECHNICAL INTEGRATION INFO EXCHANGE REVIEW GROUP FOR AGING AND LIFE EXTENSION l
AGENCY WIDE COORDINATION AND INTEGRATION OF
- TECHNICAL ISSUES l
l
(
l
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RESOURCE REQUIREMENTS CLOSE MANAGEMENT ATTENTION 1 FULL-TIME TASK MANAGER REVIEW ASSISTANCE FROM STAFF TECHNICAL EXPERTS ATTORNEY - PART-TIME TECHNICAL ASSISTANCE es EXTENSIVE AGING RESEARCH PROGRAM - NPAR FY86 $3.6M, lJ FY87 $5.2M, FY88 $8.2M, FY89 $11.0M DEDICATED NRR IllDIVIDUAL AS PolNT OF CONTACT TECHNICAL ASSISTANCE ($K)
FY87 FY88 FY89 FY90 MITRE (POLICY ANALYSIS) $300 $300 $200 $200 TBD (PRA EVALUATION) $200
'TBD (TECHillCAL ANALYSIS) $300
$300 $500 $500 $200
-NOTE: TECHNICAL ASSISTAllCE $'S ARE PRELIMINARY ESTIMATES SUBJECT TO REVIS10N AS ISSUES ARE IDENTIFIED
+
O 4
IflDUSTRY LIFE EXTEllSION ORGAllIZATI0fis i
1 flUMARC - EXECUTIVE OVERSIGHT NUPLEX STEERING COMMITTEE - OVERALL INDUSTRY C00RDillATION AND INTERFACE WITH NRC (G. NEILS, CHAIRMAff -.D. HOSTETLER, VICE CHAIRMAN)
I TECHNICAL SUBCOMMITTEE
^
(L. DELGEORGE, CHAIRMAN)
O -
CODES AND STANDARDS SUBCOMMITTEE c
- (E. MERRICK, CHAIRMAN)
LICENSING SUBCOMITTEE i- (D. EDWARDS, CHAIRMAN) i-owl 4ERS GROUPS (B8W, BWR, CE, W)
"'"^c' "S O
C
O v
INDUSTRY ACTIVITIES HUPLEX AIF/NESP PUBLIC COMMENTS - 57 RESPONDENTS 42 FROM NUCLEAR INDUSTRY (2 CONSIDER EFFORT PREMATURE) 7 PRIVATE CITIZENS (4 OPPOSED, 2 FOR, 1 QUALIFIED) 2 PUBLIC INTEREST GROUPS (1 OPPOSED, 1 NO OVERALL POS.)
2 FEDERAL AGENCIES 1 STATE AGENCY (WIS.PSC) (FOR) 3 INDEPENDENT CONSULTANTS (1 OPPOSED, 1 FOR, 1 NO OVERALL POS.)
([)
- NUPLEX SUBMITTAL THE LARGEST AND MOST THOROUGH
" REGULATORY CONSIDERATIONS FOR EXTENDING THE LIFE OF NUCLEAR POWER PLANTS," AIF/llESP-040 LIFE EXTENSION TECHNICAL PROGRAMS SURRY a MONTICELLO PILOT STUDIES ASSESSMENT OF CRITICAL COMPONENTS COMPARE DESIGN CRITERIA WITH CURRENT CODES AND CRITERIA EXPANDED EVALUATION OF REACTOR INTERNALS IDENTIFY MAINTENANCE AND INSPECTION PROCEDURE CHANGES SUPPORTIVE OF PLEX ETC.
VARIANT STUDIES WITH DUKE POWER AND BGaE INDUSTRY TOPICAL REPORTS O
AIF/NESP TASK FORCE
() RESPONSIBLE FOR DEVELOPING AIF/NESP-040
" REGULATORY CONSIDERATIONS FOR EXTENDING THE LIFE OF NUCLEAR POWER PLANTS" CHAIRMAN - DENNIS COX SOUTHERN CALIFORNIA EDISON MEMBERSHIP - UTILITIES, A&E, VENDORS, DOE, EPRI, CONSULTANT CONTRACTOR GROVE ENGINEERING INC.
FRIED, FRANK, HARRIS, SHRIVER AND JACOBSON TECHNICAL RESEARCH R. WALKER /C. NEGIN/
H. FEINROTH LEGAL RESEARCH M. ROWDEN/J. KRAEMER PROJECT ADVISORY GROUP:
J. M. HENDRIE (CONSULTANT - FORMER NRC CHAIRMAN)
C. LARSON (NSP - VICE PRESIDENT)
J. T. RHODES (VIRGilll A POWER - VICE PRESID3!T)
M. SHAW (CONSULTANT)
O (STRATTON & ASSOC. - FORMER ACRS W. R. STRATTON MEMBER
f
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[
SLIDE # 8 O .
. nr. Tier:
Establish Policy e
principles and objectives
. scope and standards for license renewal a
review time
- application timing
. Identify regulations to be changed
. public comment V
Second Tier:
Modify Regulations
. modify timely renewal period 10CFR50.51, need for a plant specific EIS?
- use of amendment versus relicensing
= other modifications identitled by the Commission
= public comment L V
Third Tier:
Provide Guidance To Licensees (examples only)
= contents of a submittal a safety review methods
. evaluations of degradation based on operating records
- . evaluations of degradation based on examinations '
=
Inspection & test in lieu of records
. evidence of non degradation for various materials i
l O
Three Tiered Approach To Establishing
(
- A License Renewal Process (
~
I
~
~
O O O ;
SLIDE # 9 l ises , im
, tear , i...
, i... ,
Soedt pubne input Estebash Pascy Develop Poney (Tier 1) :
z
,I lg h
O teodify Reguletions (Tier 2) 1 *>a
(' j*
l **' I Roe o**e (1st issuance)
Re*.d Reg Gdses
< -Review kdmey Reports.etc O Stoff Ovidence (Tier 3)
, -Review Codes and Standards
, revies },
E i s
dochet i
Act on First Appncetions g,ygg, ,
i *
- i l Aret econee renewed Act en Fenow on Appucatione i
I
' >ct 2in j E .mwwwwwwwwwmmmwwmmwwwwwmwwwwmmwwwwwwwwwwmwwwwwmmwwumwmmwwwwmmww Podle input so connent on goe Tiere 18 2 NRC poAcy development
-l draft NRC poscy and ndes ,
D i t
- aOkw PE84 Pol *C#
a l
z < iD >
-U i gg8
- .a Tl" 8 eeier musuety Rs0 enorm:
, edwnit m NRC and lawate conenent on Reg Oste revisions
- f Z (topicud reports. toAed codes and
- -su a siendwde, penwie guides sor scense 3OE , renewal applicasons, etc
'***"h*MM*NmMwwMwwmmwmmmmwwwmmmmmmwm%gg%%%,
i Licensees 8 '" W
- d'hi=a J ,-4 Per cuput of peat piant P --L - Rs0 so i 2 U FIrW eppnconte develop and papere lead renewal e 3 l e interact wSRC ,
y appovo as i
Follow-on Applicente n % and propero renewas e% , NRC acdon en - - - - '
to i -
2 l
O doctet Aret
- routhe* appeceGon SCHEDULE FOR DEVELOPMENT OF NRC POLICY / PROCESS FOR LICENSE RENEWAt.
I
. c SLIDE # 10 0
THEMES RE: APPROAdH (CHAPTER 5 - SECTIONS 5.2 TO 5.9)
THEME 1 - THE CONTINUITY THEME
" EXTENDING PLANT LIFE BEYOND 40 YEARS 15 A REAFFIRMATION OF THE ONGOING AND CONTINUOUS PROCESS OF HARDWARE RENEWAL TelAT IS AN INTEGRAL PART OF EVERY NUCLEAR POWER PLANTS OPERATING PROGRAM. . .
THE PRACTICE OF FOCUSING ON SPECIFIC DEGRADATION MECHANISMS AND ESTABLISHING CRITERIA TO ASSURE CONTINUED SAFETY OF THE PUBLIC IS THUS ALREADY AN ESTABLISHED POUCY AT THE NRC. LICENSE RENEWAL CAN BE VIEWED AS A CONTINUATION OF THIS POLICY, AND AN OPPORTUNITY TO OVERSEE ITS OVERALL APPLICATION TO BE SURE NOTHING HAS BEEN
"'SS" '
O THEME 2 THE EXTANT LICENSING BASIS CONCLUSION
" BASED ON THE OVERALL SAFETY RECORD OF NUCLEAR POWER PLANTS DURING THEIR INITIAL TERMS, IT DOES NOT SEEM APPROPRIATE FOR NRC TO INCLUDE NEW CRITERIA IN THE SAFETY EVALUATION OF INDIVIDUAL COMPONENTS OR STRUCTURES FOR UCENSE RENEWAL ITIS RECOMMENDED ,
THAT THE OVERALL COMMISSION POLICY BE ESTABLISHED ON THIS PREMISE."
O -
n)
KEY ELEMENTS OF INDUSTRY POSITION PRICIPLES RENEWAL PROCESS DEALS WITH A XNOWN ENTITY FOCUS ON AGE-RELATED DEGRADATION OF SAFETY-RELATED EQUIPMENT MAINTENANCE OF THE EXISTING LEVELS OF SAFETY MAINTENANCE OF THE EXISTING LICENSE / DESIGN BASIS FLEXIBILITY NEEDED
()
MANIFESTATION ENVIRONMENTAL ASSESSMENTS ARE ADEQUATE PROCESS LOOKS LIKE AN AME.NDMENT O .
O
~
L
POLICY ISSUES O,
UEW LICENSE VS. AMENDMENT FLEXIDILITY IN TIMIflG LICENSE RENEWAL TERM OF RENEWED LICEllSE TIMELY RENEWAL DOCTRINE ENVIR0llMENTAL REVIEW PUBLIC HEAR!flGS APPLICABILITY OF EXISTING REGULATORY CRITERIA THE BACKFIT RULE ROLE OF THE SAFETY G0AL WEIGHT GIVErl TO MANAGEMEllT PERFORMAf1CE EMERGENCY PLANNii1G IMPLICATI0t1S DECOMMISS10t11NG O
- HIGH LEVEL WASTE PRICE-ANDERSON ANTITRUST TECHNICAL ISSUES DEFINIf1G THE PHYSICAL SCOPE OF LICENSE REllEWAL EVALUATIflG COMPONEf4TS AND STRUCTURES SUBJECT TO AGE-RELATED DEGRADAT10ft OPERAT10f1AL PERFORMANCE AND RECORDS ORIGINAL DESIGN LIFE O
- ROLE OF PROBABILISTIC RISK ASSESSMENT
~>
U EXAMPLES OF POLICY OPT 10lls MEET LICENSING CRITERIA THAT EXISTS AT THE TIME OF LICENSE APPLICAT!0ft ISAP SEP TYPE REVIEW PRA-SHOW PLANT MEETS SAFETY G0ALS REQUIRE ENHANCEMENTS !!1 MAINTENANCE, SURVEILLANCE, AND O Ree'^ CEMENT eaooRAMS TO ENSURE AGE-RELATED DEGRADAT10fj IS MINIMlZED DO NOTHING DIFFERENTLY IN REGULATING PLANT DO NOT RENEW LICENSES l0
C)
HIGH VISIBILITY PROGRAM CONGRESS (MARKEY, BREAUX) HAVE WRITTEN LETTERS LINKING SURRY WITH LICENSE RENEWAL.
GAO HAS 2 STAFFERS ATTENDING MEETINGS AT REQUEST OF MARKEY.
GAO STAFFERS INDICATED THERE IS SOME CONCERN OVER INDUSTRY EFFORTS ON POLICY DEVELOPMENT.
POLICY DEVELOPMENT PROGRAM WILL BE HELD TO MAXIMIZE PUBLIC PARTICIPATION.
4
(^')
N_/
CONCLUSIONS THE STAFF HAS BEGUN A PROGRAM WHICH CAN BE EXPECTED TO RESULT IN PUBLICATION OF POLICY STATEMENT IN 1989 AND FINAL REGULATIONS FOR LICENSE RENEWAL BY 1992.
PROCEDURES ARE BEING DEVELOPED TO ASSURE OPENNESS AND ADEQUATE PUBLIC PARTICIPATION.
EFFORTS ARE UNDERWAY TO ASSURE C0 ORDINATION WITHIN NRC.
rm.
U
- RESOURCE REQUIREMENTS ARE BEING IDENTIFIED NOW AND WILL INVOLVE TECHNICAL ASSISTANCE DEDICATED, TECHNICAL RESEARCH, AND TECHNICAL STAFF.
INDUSTRY ACTIVITIES ARE BEING CLOSELY MONITORED.
SO FAR INDUSTRY INTERACTION HAS BEEN FOCUSED ON RELICENSING POLICY RATHER THAN THE TECHNICAL BASIS FOR RELICENSING.
I BRIEFING TO COMISSION ON DRAFT NRC STRATEGIC PLAN 1
i BY:
STRATEGIC PLANNING STEERING GROUP l
t G G G
L1: . .
il .
-i ll i STRATEGIC PLANNING PROCESS i ,
\
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- l. NRC NilSSION j
STRATEGIC %
i3 PLANNING GROUP I N i
j RESPONSIBILITY ASSUMPTIONS
, OVERALL GOALS #-
i
! p# i i .
i 1 f SPECIFIC GOALS If AND STRATEGIES
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ACTION PROGRAMS I FOLLOW-ON '
EFFORT If -
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' BUDGET '
f! If
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STRATEGIC PLANNING APPROACH IDENTIFIED EIGHT MAJOR GOALS FOCUSED ON POTENTIAL CHANGES TO TODAY'S APPROACHES TO ACHIEVE MAJOR GOALS ADDED APPROACHES THAT SHOULD NOT BE CHANGED PLAN REPRESENTS COLLECTIVE JUDGMENTS OF SENIOR MANAGERS NO DETAILED ANALYSIS OF ASSUMPTIONS OR ALTERNATIVE STRATEGIES PROGRAMS AND RESOURCES TO IMPLEMENT STRATEGY NOT WITHIN SCOPE OF THIS EFFORT PROGRAMS AND RESOURCES WILL BE DEVELOPED IN NEXT PHASE OF FIVE-YEAR PLAN DEVELOPEMENT RESEARCH GOALS AND STRATEGIES ARE BEING ENHANCED TO INCLUDE:
RESEARCH PHILOSOPHY RELATED MODIFICATION TO GOALS AND STRATEGIES 2
O O O
O *
SUMMARY
OF MAJOR ASSUMPTIONS END OF AN ERA 0F LICENSING NEW REACTORS CONTINUATION OF A RELATIVELY LARGE NUMBER OF OPERATING REACTORS AND NON-REACTOR LICENSES CONTINUATION OF A RELATIVELY UNCHANGED SAFEGUARDS ENVIRONMENT VARIATION IN OPERATIONAL PERFORMANCE OF NRC LICENSEES EMPHASIS ON WASTE MANAGEMENT BEGINNING OF POSITIONING FOR FUTURE LICENSING ACTIVITIES INCREASING INVOLVEMENT OF STATE AND LOCAL GOVERNMENTS AND AGENCIES IN NRC-REGULATED ACTIVITIES 3
e G G
OVERALL G0ALS ENSURE THAT CURRENT NUCLEAR POWER PLANTS OPERATE SAFELY ENSURE THAT NUCLEAR POWER PLANTS UNDER CONSTRUCTION ARE DESIGNED AND CONSTRUCTED PROPERLY AND ARE READY FOR SAFE OPERATION PREPARE FOR FUTURE REACTOR LICENSING ACTIVITIES ENSURE THAT THE CURRENT AND FUTURE USES OF NUCLEAR AND RADI0 ACTIVE MATERIALS ARE SAFE AND HAVE ADEQUATE SAFEGUARDS ENSURE THAT NUCLEAR WASTE IS SAFELY MANAGED ENSURE THAT RESEARCH PROVIDES THE TECHNICAL BASES FOR TIMELY AND SOUND RULEMAKING AND REGULATORY DECISIONS IN SUPPORT OF NRC LICENSING AND INSPECTION ACTIVITIES ALLOCATE NRC'S CAPITAL AND HUMAN RESOURCES AND DIRECT THE AGENCY'S AFFAIRS SO THAT THEY CONTRIBUTE MOST EFFECTIVELY TO THE MISSION OF PROTECTING THE PUBLIC HEALTH AND SAFETY AND TO ITS RESPONSIBILITY TO KEEP THE.PUBLIC FULLY INFORMED OF SAFETY-RELATED MATTERS ENSURE INDEPENDENT REVIEW 0F NRC ACTIVITIES 4
O O O
CHANGES IN AGENCY APPROACHES FOR ACHIEVING G0ALS AN EMPHASIS ON BEING PROACTIVE RATHER THAN REACTIVE MORE DIFFERENTIATION IN REGULATORY APPROACH ON THE BASIS OF PERFORMANCE AND POTENTIAL RISK ENHANCED INCENTIVES FOR EXEMPLARY PERFORMANCE AND IMPROVEMENTS IN LICENSEE OPERATIONS MORE ACTIVE ROLE OF LICENSEES IN PURSUIT OF EXCELLENCE IMPROVED AND MORE FOCUSED RESEARCH IN SUPPORT OF THE AGENCY MISSION ENHANCED PUBLIC UNDERSTANDING OF THE NRC AND ITS IMPORTANCE IN PROTECTING SAFETY, THE COMMON DEFENSE AND SECURITY, AND THE ENVIRONMENT IMPROVED ALLOCATION OF AGENCY RESOURCES RELATIVE TO RISK DETERMINATION IMPROVED UTILIZATION AND ALIGNMENT OF NRC HUMAN RESOURCES 5
O O O
^
w MAJOR FEATURES OF G0AL AND STRATEGIES FOR REACTOR AND NON-REACTOR OPERATIONS ESTABLISH STANDARDS FOR, AND MEASURES OF, PERFORMANCE IDENTIFY WHEN THE POTENTIAL FOR EVENTS AND ACCIDENTS INCREASES AND TAKE PREVENTIVE ACTIONS ENCOURAGE EXCELLENCE IN LICENSEE PERFORMANCE BY PROVIDING INCENTIVES AND DISINCENTIVES CONTINUE TO RECOGNIZE THE UNCERTAINTY IN ACCIDENT PREDICTION PROVIDE REGULATORY PROGRAMS COMMENSURATE WITH RISKS 6
O O O
MAJOR FEATURES OF G0AL AND STRATEGIES FOR CURRENT AND FUTURE LICENSING CONTINUE TIMELY REVIEW AND LICENSE DECISIONS FOR REACTORS UNDER CONSTRUCTION WITH EMPHASIS ON:
QUALITY OF CONSTRUCTION TRANSITION FROM CONSTRUCTION TO OPERATION PREPARE NOW FOR FUTURE REACTOR LICENSING ASSOCIATED WITH:
LICENSE EXTENSIONS DECOMMISSIONING STANDARDIZATION ADVANCED REACTORS PUT IN PLACE REGULATORY PROGRAM FOR HIGH-LEVEL AND LOW-LEVEL WASTE MANAGEMENT 7
i O O O
MAJOR FEATURES OF G0ALS AND STRATEGIES FOR INTERNAL AND EXTERNAL OPERATIONS PROMOTE A COORDINATION WITH STATE AND LOCAL GOVERNMENTS PROACTIVELY INFORM PUBLIC IMPROVED PRIORITIZATION AND PLANNING OF AGENCY'S PROGRAMS AND RESOURCES PROVIDE EFFECTIVE AND EFFICIENT MANAGEMENT DEVELOP AND MAINTAIN A HIGHLY TRAINED AND MOTIVATED STAFF CONTINUE INDEPENDENT NRC SAFETY AND JUDICIAL OVERSIGHT i
I 8
O O O
c . .
NEXT STEPS o STRATEr,TC PLAN ENHANCE RESEARCH SECTION CONSIDER ALL NRC MANAGERS' VIEWS SUBMIT FINAL STRATEGIC PLAN TO COMMISSION COMMISSION APPROVAL OF PLAN JUNE 10 ANNUALLY REVIEW AND UPDATE PLAN o COMPLETE NEXT PHASE OF FIVE-YEAR PLAN INITIATE WHILE STRATEGIC PLAN IS BEING FINALIZED 9
O O O
O 33S STAPP PR3SESTAT OX TO "-3 AC:RS SUBJECf: INITIATION OF Tile SEVERE ACCIDENT POLICY INDIVIDUAL PLANT EXAMINATION DATE : JUNE 51987 q p PRESENTER: FRANKLIN C0FFMAN PRESENTER'S TITLE /DIV: ACTING BRANCH CIIIEF REllABILITY& IlUMAN FACTORS BRANCII DIVISION OF REALTOR AND PLANT SYSTEMS OFFICE OF NUCLEAR REGULATORY RESEARCII PRESENTER'S NRC TEL N0.:(301) 492-4c09 P
4 O ToerCs soR Discussion
- o- GENERIC ~ LETTER T0 INITIATE THE IPEs .
O GOALS AND SCOPE OF IPEs a
o GENERIC LETTER PACKAGE TO A UTILITY O o SCHEDULE .
o IDOCR PRESENTATION s
i l0 I
i
{- 1 ,
L,..._---__ _ __ _
O O U -
SEVERE ACCIDENT F0LICY STATEENT - ACTIm ITDE POLICY STATEE NT NEW APPLICATIONS EXISTING PLANTS o GlJIDANCE ON TIE ROLE o SYSTB % TIC APPROACH OF PRAs FOR TE EXtNIt!ATION OF Il0lVIDUAL PLANTS 9
o PEFf0ffANCE CRITERIA o IMPLB1ENT P0DIFICATION FOR C0tITAltPENT TIM W H BACKFIT POLICY SYSTRE o CF# GES IN RULES ATO PECLA_ATORY PPACTICES, AS PEEDED
O ceNenIC te1TeR PE00EST FOR INDIVIDUAL PLANT EXAMINATIONS BASIS: COMMISSION SEVERE ACCIDENT POLICY STATEMENT OF THE NEED TO ASSURE THAT NO VULNERAPILITIES TO SEVERE ACCIDENTS EXIST AT INDIVIDUAL PLANTS FORMAT:- 10 CFR 50.54(F) REQUEST SIGNATURE: DIRECTOR NRR ATTACHMEl4TS: PLANT SPECIFIC O
3
9
) GOALS AND OBJECTIVES OF IPE:
o TO IDENTIFY INDIVIDUAL PLANT VULNERABILITIES TO SEVERE ACCIDENTS IF ANY (FOR BOTH CORE DAMAGE AND CONTAINMENT PERFORMANCE).
o TO IDENTIFY POTENTIAL IMPROVEMENTS FOR AN INDIVIDUAL PLANT TO RESPOND TO SEVERE ACCIDENTS, c TO EVALUATE MEANS FOR IMPROVING PLANT / CONTAINMENT PERFORMANCE AND FOR-COPING WITH ANY VULNERABILITIES.
O'
'~
o TO IMPLEMENT IMPROVEMENTS AND ANY CORRECTIVE ACTIONS, I.E., INCORPORATE THE IPE KNOWLEDGE AND INSIGHTS INTO AN ACCIDENT MANAGEMENT SCHEME ( WHICH INCLUDES ORGANIZATIONAL RESPONSIBILITIES, OPERATING PROCEDURES, TRAINING PROGRAMS, NEEDED INSTRUMENTATION).
r~s -
N-4
O CONSIDERATION OF EXTERNAL HAZARDS IN IPEs (SECY-86-162) o BOTH IDCOR AND NRC WORK HAS BEEN FOCUSED ON INTERNAL HAZARDS, o EXTERNAL HAZARDS NEED TO BE CONSIDERED.
o SCHEDULE FOR EXTERNAL HAZAPDS CAN FOLLOW AFTER THE INTERN HAZARDS IPEs.
O e PROGRAM STEPS:
- 1. DEFINE THE EXTENT TO WHICH PLANTS WERE REVIEWED FOR EXTERNAL HAZARDS,
- 2. USE THE SSMR AND SDMR PROGRAM METHODS TO ESTIMATE MAR AGAINST EXTERNAL HAZARD THAT PAST REVIEWS PROVIDED.
l 3. IDENTIFY SELECTED PLANT FEATURES THAT SHOULD BE EXAM BY A SEPARATE IPE FOR EXTERNAL HAZARDS, IF ANY.
l
- 4. PROVIDE GUIDANCE FOR THE EXAMINATION BY A SEPARATE FOR SELECTED EXTERNAL HAZARDS.
4
(])
I 5
n SCOPE OF IPE c OUESTIONS WILL REMAIN ABOUT THE COMPLETENESS OF PLANT ANAL DUE TO LARGE UNCERTAINTIES ASSOCIATED WITH SOME GENERIC ISS SUCH AS THE POTENTIAL FOR EARLY CONTAINMENT FAILURE VIA DIRE CONTAINMENT HEATING AND UNCONTROLLED HYDROGEN EURNING.
o HOWEVER, THERE ARE SUFFICIENT SAFETY BENEFITS TO BE OBTAINED BY PROCEEDING WITH THE IPEs AND A SEVERE ACCIDENT MANAGEME SCHEME. THE SAFETY BENEFITS INCLUDE UTILITY INVOLVEMENT IN
(~1 x
GAINING A WORKING KNOWLEDGE OF SEVERE ACCIDENT RESPONSES A ITS PLANT AND FURTHERING PREPARATIONS TO PREVENT AND MITIG LEADING SEVERE ACCIDENTS.
(v^^,
6
GENERIC LETTER PACKAGE TO UTILITY kO RES WILL PREPARE THE PACKAGES FOR NRR T0 ISSl!E TO ALL RE0L'ESTING INDIVIDUAL PLANT EXAMINATIONS (IPE) IN ACCOR THE SEVERE ACCIDENT POLICY STATEMENT, EACH PACKAGE WILL CONTAIN:
o GENERIC LETTER ,
o GUIDELINES AND CRITERIA BY PLANT TYPE o APPLICAELE IDCOR IPEM EVALUATION O
o REFERENCE LIST
- NUREG-1150, NUREG/CR-4550, NUREG/CR-455),
NUREG/CR-4700, NUREG/CR-4624 IDCOR PROGRAM TECHNICAL REPORTS O
7
O generic tetter CON 1eNT o INITIATE THE IPE PROCESS
- A SYSTEMATIC EXAMINATION OF PLANT DESIGN, OPERATION, MAINTENANCE AND EMERGENCY OPERATION, IDENTIFICATION OF LEADING SEVERE ACCIDENT SE0VEPCES FOR THE PLANT,
- IDENTIFICATION OF MAIN CONTRIBUTORS (HARDWARE, PROCEDURES, TRAINING, MAINTENANCE) TO BOTH CORE DAMAGE FREQUENCY AND CONTAINMENT PERFORMANCE.
COMPARISON WITH APPLICABLE GUIDELINES AND CRITERIA TO CHECK AGAINST IMPORTANT AND DESIRABLE PLANT FEATURES AND OPERATIONS, IDENTIFICATION OF POTENTIAL IMPROVEMENTS WITH PESPECT TO BOTH ACCIDENT PREVENTION AND ACCIDENT MITIGATION,
- EVALUATION OF POTENTIAL If1PPOVEMENTS, DOCUMENTATION OF THE LICENSEE'S EVALUATION, DECISION CRITERIA, AND JUDGEMENT,
- PROPOSE IMPROVEMENTS FOR THE PLANT, PROVIDE JUSTIFICATION FOR IMPROVEMENTS NOT RECOMMENDED, o THE GENERIC LETTER SPECIFIES 5 OPTIONS THAT COULD BE USED FOR THE SYSTEMATIC EXAMINATION:
IDCOR IPEM LEVEL - 11 OR - Ill PRA LEVEL - 1 PRA SUPPLEMENTED WITH CONTAINMENT ANALYSIS SIMPLIFIED PRA WITH APPROVAL Q
OTHER SYSTEMATIC EVALUATION METHODS WITH APPROVAL 8
O UTILI7ATION OF PAST EXPERIENCE AND INSIGHTS (GUIDELINES AND CRITERIA) o GUIDELINES IDENTIFY THOSE PLANT FEATURES AND OPERATOR ACTIONS '
THAT WERE FOUND TO BE IMPOPTANT TO RISK IN PREVIOUS STUDIES, o GUIDELINES HIGHLIGHT (NOT SPECIFY) POTENTIAL AREAS OF IMPROVEMENTS IN PLANT DESIGN AND OPERATIONS.
o CRITERIA ARE THE STANDARDS OR ATTRIBUTES CONSIDERED APPROPRIATE FOR ASSESSING THE PERFORMANCE OF PLANT FEATURES OR OPERATOR ACTIONS IDENTIFIED IN THE GUIDELINES, c THE GUIDELINES AND CRITERIA ADDRESS:
IMPORTANT E0VIPMENT TO SURVIVE THE SEVERE ACCIDENT CONDITIONS
- EQUIPMENT CAPABILITIES, CAPACITIES, AND OPERABILITY ACCESSIBILITY TO EQUIPMENT
- AVAILABILITY OF SUPPORT SYSTEMS AND IMPORTANT COMPONENTS IDENTIFICATION OF IMPORTANT OPERATOR ACTIONS IDENTIFICATION OF INDICATORS T0 INITIATE MITIGATING SYSTEMS AND OPERATOR ACTIONS o DEVELOPED USING:
- OVER 20 PRAs PERFORt1ED FOR U.S. PLANTS, (NRC AND NRC CONTRACTORS REVIEWED APPROXIMATELY 10 PRAs).
D'SCUSSIONS AND SEMINARS WITH INDUSTRY EXPERTS WHICH O INCLUDED EXPERIENCE VITH FOREIGN REACTORS 9
O - Review AnD DrSCUSSiONS Wi1a iDCOR ON Tse1R r0uR REFERENCE PLANTS.
- NRC ANALYZED FIVE REFERENCE PLANTS Oll!P.EG-1150); THE DETAILED ANALYSES ARE DOCUMENTED IN 20 CONTRACTOR REPORTS.
o THE AVAILABLE KNOWLEDGE WAS SCREENED Af1D REVIEWED FOR SEVERE ACCIDENT INSIGHTS CORE DAMAGE SEQUENCES GREATER TFAN 1E-6/RY.
SEQUENCES CONTRIBUTING GREATER THAN 5% OF THE TOTAL CORE DAMAGE FREQUENCY.
- CONTAINMENT FAILURE IN LESS THAN ONE DAY, CONTAINMENT BYPASS MORE LIKELY THAN 1E-7/RY.
UNIQUE CONTRIBUTORS JUDGED IMPORTANT.
o THE INSIGHTS GAINED WERE COLLECTED TOGETHER, SORTED ACCORDING TO APPLICABLE REACTOR TYPES, AND TRANSFORMED INTO GUIDELINES AND CRITERIA FOR THE INDIVIDUAL PLANT EXAMINATIONS (IPE).
FIVE SETS OF GUIDELINES AND CRITERIA REPRESENTING DIFFERENT CONTAINMENT TYPES WERE CIRCULATED FOR COMMEllTS.
- THE LAST SET OF COMMENTS WERE RECEIVED MARCH 1, 1987.
- A REVIEW MEETING WITH REPRESENTATIVES FPOM SANDIA, ORNL, BCL AND BNL WAS HELD ON FEBRUARY 25, 1987.
- REVISED, FINAL GUIDELINES AND CRITERIA ARE AVAILABLE FOR CRGR AND ACRS REVIEW, -
Q 10
b
() o DOCUMENTATION PROVIDE THE BASES FOR THE FINDIFGS IN A TRACEABLE MANNER Th'0 TIERS OF DOCUMENTATIONS TIER-1 REPORTS THE RESULTS OF THE EXAMINATION TO NRC o LIST THE LEADING SEQUENCES AND SCREEFING CRITERIA o IDENTIFY AND LIST THE MAIN CONTRIBUTORS FOR CDF AND CONTAINMENT FAILURE '
o DISCUSSIONS OF POTENTIAL AREAS OF IMPROVEMENT o EVALUATIONS OF POTENTIAL AREAS OF IMPROVEMENT
[)
o DESCRIPTION OF THE SEVERE ACCIDENT MANAGEMENT SCHEME TIER-2 DOCUMENTS THE EXAMINATION AND WOULD BE RETAINED BY LICENSEES, E.G., SYSTEMS NOTEBOOKS, VISUAL INSPECTIONS RECORDS, CALCULATIONS.
f 4
i i 11
(]) SEVEPE ACCIDENT MANAGEMENT SCHEME o PURPOSE: TO ASSURE THAT THE IPE INSIGHTS ARE ASSIMILATED INTO THE DESIGN AND OPERATIDFS OF THE PLANT o APPROACH: DEVELOP AN OVERALL STRATEGY TO STRENGTHEN THE PLANT'S ABILITY TO RESPOND TO SEVERE ACCIDENTS BASED UPON THE IPE DETERMINATION OF THE LEADING SEVERE ACCIDENT SE00ENCES, THE MAIN CONTRIBl! TORS FROM THOSE SEQUENCES, THE POTENTIAL AREAS FOR IMPROVED PREVENTION AND MITIGATION, ASSUMED REC 0VERIES AND RESPONSIBILITIES, AND EXISTENT CAPABILITIES.
o INGREDIENTS:
V, s
- ORGANIZATION: DELINEATE RESPONSIBILITIES AND COMMUNICATIONS LINES
- PROCEDURES: IDENTIFY ACTIONS AND INSTRUCTIONS
- TRAINING: REVISE TRAINING PROGRAMS TO INCLUDE NEEDED ORGANIZATIONAL LEVELS AND THE POSSIBLE OUTCOMES FROM THE SEVERE ACCIDENT SEQUENCES.
- INSTRUMENTATION: DETERMINE THE INSTRUMENTS AND THEIR SURVIVABILITIES NEEDED TO SUPPORT BOTH SEVERE ACCIDENT DIAGNOSTICS AND CORRECTIVE ACTIONS.
~
()
o
()
CHRONOLOGY AND SCHEDULE o THE IPEM, GUIDELINES 8 CRITERIA, SCOPE OF THE EXAMINATION AND GENERIC LETTER HAVE EEEN DISCUSSED WITH THE ACRS SUBCOMMITTEE, LATEST MEETING WAS MAY 28, 1987. ACRS MEETING JUNE 5. LETTER IS EXPECTED IN JUNE 1987, o AN INFORMATION MEETING WITH CRGR WAS HELD IN OCTOBER 1986.
CRGR MEETING WILL BE SCHEDULED FOR JUNE 1987, o A COMMISSION MEETING FOR APPROVAL T0 ISSUE THE GENERIC LETTER WILL BE SCHEDULED FOR JULY 1987, o ISSUE' GENERIC LETTERS WITH REQUEST FOR INDIVIDUAL PLANT EXAMINATIONS (IPEs) JULY 1987 o CONDUCT REGIONAL MEETING WITH UTILITIES TO DISCUSS THE IPE PROCESS o LICENSEE SUPMIT ACTUAL SCHEDULE IN 90 DAYS, o IPEs APE EXPECTED TO BE COMPLETED IN 2 1/2 YEARS.
O PRIORITY FOP IPE IsT PLANTS WITH NO PPEVIOUS EXAMINATIONS 2ND PLANTS WITH EXISTING PRA AND IPEM TEST PLANS 3RD PLANTS WHICH WILL PERFORM A FULL-SCOPE PRA AND NEED MOR TIME.
(S) 13
o o o l
STATUS OF IDCOR '
INDIVIDUAL PLANT EVALUATION METHODOLOGYI 1 l
i IN RESPONSE TO THE SEVERE ACCIDENT POLICY STATEMENT l
l A.R.BUHL i
! PRESENTED TO: 'l THE ADVISORY COMMITEE FOR REACTOR SAFETY .l
-l JUNE 5,1987 WASHINGTON, D.C.
I
\0 0
^
O '
! IDCOR PROGRAM BEGAN IN LATE 1980 i
IN RESPONSE TO TMI ACCIDENT WITH TECHNICAL & REGULATORY MISSION ;
l TO RESOLVE SEVERE ACCIDENT QUESTION TO DEVELOP COMPREHENSIVE, INTEGRATED, WELL-DOCUMENTED, TECHNICALLY SOUND POSITIONS ON SEVERE ACCIDENT ISSUES -
L
- TO SERVE AS THE U.S. INDUSTRY SPOKESMAN i
i WITH U.S. NRC ON SEVERE ACCIDENT ISSUES j i
l l
68482332
- i O .
O .
O
! t i
i IDCOR HAS STRONG U.S. a i
i AND INTERNATIONAL SUPPORT 63 U.S. UTILITIES 4 NSSS VENDORS i
! 9 ARCHITECT ENGINEERS
- FINLAND '
i GERMANY
! JAPAN SWEDEN TAlWAN I
l l
I SM uu 3 -
j . -
O O O .-
- 'IDCOR HAS PROGRESSED IN THREE PHASES l 1981-1985 - TECHNICAL PROGRAM ~
1985-1986 - ISSUE RESOLUTION WITH U.S. NRC IPE METHODOLOGY DEVELOPMENT SOURCE ~ TERM & EMERGENCY PLANNING FINAL ISSUE RESOLUTION l
1986 - IPE TESTING ON 8 PILOT PLANTS
- EMERGENCY PLANNING SUPPORT
~
- CHERNOBYL IMPACT EVALUATION e
1 1 .
~
O O IkOR ESTABLlSHED A SEPARATE ORGANIZATION '
I TO RESOLVE SEVERE ACCIDENT ISSUES i
] .
1 POLICY GROUP PERRY BRITTAIN j CHAIRMAN I
STEERING GROUP ATOMIC INDUSTRIAL
- CORDELL REED FORUM
- CHAIRMAN ROGER HUSTON l
j - :
I ! .
j : PROGRAM MANAGER '~!
INTERNATIONAL t
- -- TECHNOLOGY CORP. [
TONY BUHL
! LEGAL ADVISOR
.l ._
GEORGE EDGAR ,
l
) TECHNICAL ADVISORY :
i i
GROUP PROJECT MANAGER ,
MILES LEVERETT JIM CARTER '
CHAIRMAN .
P SENIOR EPRI COORDINATION GROUP ,
CONSULTANTS MARIO FONTANA '
1 CHAIRMAN t I -
23 SEPARATE CONTRACTORS i
~
i 4
6SSS253 6 '
s 4
3 CURRENT RISK -
CORE DAMAGE -
STATUS PREVENTION .
i i
t O -
CONTAINMENT EFFECTIVENESS MITIGATION p
4
. i t
i O
l l
l .
O O O -
IDCOR PERFORMED AN EXTENSIVE EVALUATION OF LWR NUCLEAR POWER PLANT RESPONSE TO SEVERE ACCIDENTS ,
INITIATING EVENTS / ACCIDENT SEQUENCES ,
j l CORE DAMAGE PREVENTION ,
SEVERE ACCIDENT PHENOMENA INTEGRATED MODELING j CONTAINMENT CAPABILITY EQUIPMENT SURVIVABILITY .
REFERENCE PLANT RESPONSE TO SEVERE ACCIDENTS MITIGATION OF SEVERE ACCIDENTS I
- OPERATOR RESPONSE TO SEVERE ACCIDENTS RISK CHANGES FROM IDCOR EVALUATIONS ~
l
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' l l IDCOR RESULTS ARE ~
i 1
EXTENSIVELY DOCUMENTED i
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A - "- -
7 IPE APPLICATION .
- 53 TECHNICAL REPORTS REPORTS
, 2 IPE METHODOLOGY
- TECHNICAL
SUMMARY
l REPORTS -
REPORT
_ _O O O
)
! GENERAL CONCLUSIONS FROM IDCOR ANALYSIS OF REFERENCE PLANTS SHOW PLANTS SAFER THAN l PREVIOUSLY PERCEIVED l
=
l A FEW ACCIDENT SEQUENCES CHARACTERIZE SEVERE ACCIDENT BEHAVIOR
=
CONTAINMENT FAILURE GENERALLY RESULTS FROM SLOW PRESSURE BUILDUP-THUS, PERCEIVED RISK DUE TO PROMPT FAILURE HAS BEEN REDUCED
=
! FISSION PRODUCT RELEASE GENERALLY LOW
= TIME IS AVAILABLE FOR l
j - OPERATOR ACTIONS
- EMERGENCY MEASURES EQUIPMENT WILL SURVIVE THESE EVENTS
=
NO NEED FOR MAJOR MODIFICATIONS
=
l RESULTS SHOW REFERENCE PLANTS ARE SAFE ENOUGH -
l l .
l- .
l_
o O O IDCOR PROVIDED A NEEDED FOCUS OF SEVERE i
ACCIDENT ISSUES i
- BUILT ON WASH 1400 AND PRA FOUNDATION j
- PROVIDED PERSPECTIVE ON KEY ISSUES EARLY CONTAINMENT FAILURE ELIMINATION CHEMICAL FORMS '
PLANT STATES OPERATOR ACTIONS TIMING OF RELEASES -
DEVELOPED SIMPLE MODELS FOR KEY ACCIDENT ISSUES
~
~
4 ,
s es sJes t .
l O O O I IDCOR PROVIDED A NEEDED FOCUS OF SEVERE l ACCIDENT ISSUES (2) 1 i
i
- DEVELOPED INTEGRATED ACCIDENT ANALYSIS j METHODOLOGY 1
i DETERMINED PLANT SEVERE ACCIDENT BEHAVIOR AS '
BASELINE FOR DECISIONS ON NEED FOR PLANT MODIFICATIONS ,
ADDRESSED NEW PHENOMENA RESUSPENSION .
REVAPORIZATION TELLURIUM BEHAVIOR RELEASE DURING CORE CO'NCRETE INTERACTIONS i See 321$ 2
i IDCOR KEY CONCLUSIONS .
4 i
PROBABILITIES OF SEVERE ACCIDENTS OCCURRING
! ARE LOW .
FISSION PRODUCT SOURCE TERMS ARE SMALLER i THAN PREVIOUSLY CALCULATED RISKS AND CONSEQUENCES TO THE PUBLIC FROM SEVERE ACCIDENTS ARE M'UCH SMALLER THAN U.S. NRC INTERIM SAFETY GOALS l MAJOR DESIGN OR OPERATIONAL CHANGES IN l REACTORS ARE NOT WABRANTED l
l
. i i
i . ,
l I '
i
O o .
O.
3 INDIVIDUAL PLANT EVALUATION IDCOR/87 OBJECTIVES j SUBMIT METHODOLOGY REVISIONS AND RESPONSES TO NRC COMMENTS DECEMBER 1986 SUBMIT GRAND GULF STUDY TO NRC FOR REVIEW DECEMBER 1986 o
i OBTAIN NRC ACCEPTANCE OF THE IPE METHODOLOGY JANUARY 1987 o
COMPLETE IPE VALIDATION ON SEQUOYAH MARCH 1987 o
NRC ISSUE GENERIC LETTER MARCH 1987 e
~
i o o o i
j i
) NRC REQUESTED.SEVERAL ADDITIONAL '
l TECHNICAL MEETINGS TO REACH CLOSURE & -
l SUPPORT REGULATORY NEED$ ~ '
l .
i MARCH 26,1985 - NRC/IDCOR TECHNICAL EXCHANGE ON '
{ '
OPEN ISSUES, INDIVIDUAL PLANT METHODOLOGY '
i
- APRIL 30,1985 - NRC/IDCOR TECHNICAL EXCHANGES '
! ON OPEN ISSUES -
i
- JULY 16,1985 - NRC/IDCOR TECHNICAL EXCHANGES ON INDIVIDUAL PLANT EVALUATION j METHODOLOGY STATUS
- SEPTEMBER 26, -
! NRC/lDCOR TECHNICAL EXCHANGE ON
- 1985 UNCERTAINTY ANALYSIS PLANS DECEMBER 9,1985-NRC/lDCOR TECHNICAL EXCHANGE ON REVISED UNCERTAINTY ANALYSIS PLANS j i2 at assa 23 i a
! e O O *
. O *
' NRC/IDCOR ISSUE RESOLUTION PROCESS
~
! SUCCESSFUL -
l l
o l IDCOR SUBMITTED TECHNICAL ISSUE l
RESOLUTION REPORT TO NRC AUGUST 1985 o
TWO TECHNICAL ISSUES RESOLVED WITH '
NO FURTHER ACTIONS REQUIRED SPRING 1985 o
PARTICIPATED IN NRC WORKSHOP ON DIRECT .
CONTAINMENT ~ HEATING A)?IL1986 o
NRC ISSUED DRAFT RESOLUTION -
POSITIONS ON THE ISSUES JUNE-SEPTEMBER 1986 o
IDCOR. RESPONSES SUBMITTED TO NRC SEPTEMBER 1986 4
i o FINAL NRC POSITIONS RECE VE3 i
O O O IDCOR & U.S. NRC REDUCED THE LONG LIST OF TECHNICAL ISSUES TO 19 BY 1985 4 MAJOR ISSUES REMAIN
- MODELING OF IN-VESSEL HYDROGEN PRODUCTION.
l
- DIRECT HEATING OF CONTAINMENT BY EJECTED j CORE MATERIAL
!
- EX-VESSEL FISSION PRODUCT RELEASE MODELS '
l
- HYDROGEN IGNITION AND BURNING '
l l
)
i 1
I l
- I .
~~
l O O Q <
i I
SEVERE ACCIDENT POLICY STATEMENT '
WITHDRAWS RULEMAKING i
! "IT ALSO SERVES AS NOTICE OF WITHbRAWAL OF THE i ADVANCED NOTICE OF PROPOSED RULEMAKlNG,
'SEVRE ACCIDENT DESIGN CRITE7IA', PUBLISHED ON OCTOBER 2,1980 (45 FR 65474)."
. l
O O O .
SEVERE ACCIDENT POLICY STATEMENT REQUIRES INDIVIDUAL PLANT EXAMINATION
- "ACCORDINGLY, WHEN NRC AND INDUSTRY INTERACTIONS ON SEVERE ACCIDENT ISSUES HAVE PROGRESSED SUFFICIENTLY TO l DEFINE THE METHODS OF ANALYSIS, THE COMMISSION PLANS TO l FORMULATE AN INTEGRATED SYSTEMATIC APPROACH TO AN l EXAMINATION OF EACH NUCLEAR POWER PLANT NOW
~
! OPERATING OR UNDER CONSTRUCTION FOR POSSIBLY
! SIGNIFICANT RISK CONTRIBUTORS THAT MIGHT BE PLANT
! SPECI.:lC AND MIGHT BE MISSED BSENT' A SYSTEMATIC l SEARCE."
i
.) s j , n .7n . , ,
O O O NRC SEVERE ACCIDENT POLICY REQUIRES EACH UTILITY TO PERFORM AN INDIVIDUAL PLANT EVALUATION (IPE)
. . . LICENSEES OF EACH OPERATING REACTOR WILL BE EXPECTED TO PERFORM A LIMITED-SCOPE, ACCIDENT SAFETY l ANALYSIS DESIGNED TO DISCOVER INSTANCES OF PARTICULAR VULNERABILITY TO CORE MELT OR.TO UNUSUALLY POOR CONTAINMENT PERFORMANCE."
/
y._ ,. ,
( -
O O O l
/
THE NRC ISSUED THE SEVERE ACCIDENT POLICY IMPLEMENTATION PLAN IN FEBRUARY
- 1986 (SECY 86-76) COMMITTING TO ISSUANCE l OF THE GENERIC LETTER JANUARY 1987 l
i l
l J is as osso is *
, e
!. O O . o
~
l NRC SEVERE ACCIDENT POLICY IMPLEMENTATION PLAN ISSUED IN 1986 .
! SUPPORTS IDCOR METHODOLOGY.
I "lDCOR HAS CONTRIBUTED IN TWO IMPORTANT WAYS . . ."
"FIRST, THEY DEVELOPED A DETAILED RISK EVALUATION -!
I METHOD AND APPLIED IT."
i "SECOND, IDCOR HAS DEVELOPED AND TESTED A i
SIMPLIFIED METHODOLOGY TO BE USED BY UTILITIES FOR ;
THE INDIVIDUAL PLANT EXAMINATIONS."
l l
l l
j
- si se esso ao '
O O O DIRCKS JULY 22 LETTER TRANSFERRED SEVERE ACCIDENT CLOSURE RESPONSIBILITY TO NRR .
FROM RESEARCH l *". . . SHIFTING FOCUS OF THIS WORK FROM RESEARCH TO REGULATORY APPLICATIONS."
= '
"I HOPE THIS METHODOLOGY (IDCOR IPE) WILL
- BE THE IMPORTANT VEHICLE FOR CLOSURE OF THE SEVERE ACCIDENT ISSUE."
"THE IDCOR EFFORT . . . HAS SET. AN EXAMPLE OF EXCELLENCE."
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) . . .. ._ ,. .
^
O _
O O
'DENTON -DECEMBER 9 LETTER COMMITS TO l IMPLEMENT COMMISSION SEVERE ACCIDENT i
POLICY IN 1986
- ". . . I WILL LOOK TO IDCOR TO COORDINATE INDUSTRY' RESPONSE AND INPUT."
- ". . . WE SEE THE IDCOR PROGRAM, METHODOLOGY AND APPROACH AS THE PROPER VEHICLE FOR DEVELOPING A l METHOD FOR SYSTEMATIC EXAMINATION OF INDIVIDUAL .
l PLANTS" .
l *". . . STAFF REVIEW OF THE IDCOR . . . COMPLETED BY i FALL OF 1986 . . ."
l l .
t a n ..u i. ,
O O O j
SEVERAL NRC/IDCOR INTERACTION MEETINGS HELD TO CLOSE ISSUES AND FACILITATE 1
1, METHODOLOGY REVIEW ,
j = APRIL 3,1986 NRC/IDCOR SENIOR MANAGEMENT EXCHANGE ON IDCOR CRITERIA j . MAY 14-15,1986 IDCOR CONDUCTED WORKSHOP l
FOR NRC ON IPE METHODOLOGY
~
3
- SEPT 22-23,1986 I NRC/IDCOR TECHNICAL EXCHANGE ON REFERENCE PLANT UNCERTAINTY ANALYSES -
- OCT 24,1986 NRC/IDCOR SENIOR MANAGEMENT MEETING ON OPEN ISSUES AND l PROGRAM CLOSURE
O O O IDCOR PREPARING INDIVIDUAL PLANT EVALUATION (IPE) METHODLOGY FOR ADDRESSING U.S. NRC SEVERE ACCIDENT POLICY STATEMENT
- IDCOR DEVELOPED METHOD LOGY IN 1985
- IDCOR SELECTED 8 REFERENCE PLANTS TO TEST APPLICABILITY OF THE METHOD TO MAJOR CONTAINMENT & REACTOR TYPES
- IDCOR BEGAN TESTING THE METHOD IN LATE SUMMER 1985
- METHODOLOGY SUBMITTED TO U.S. NRC FOR REVIEW & COMMENT APRIL 1986
- U.S. NRC GIVEN RESULTS OF 5 TEST CASES IN l JUNE 1986 U.S. NRQ. REVIEW & POLICY IMPLEMENTATION DOCUMENTS EXPECTED IN OCTOBER,1986 l
. .m . . ,
l
O O .
O .
INTENSE IPEM EFFORTS ARE NEAR COMPLETION o MET-ODOLOGY REV SED BEFORE SUBMITTAL TO NRC MARCH 1986 o
MET-lODOLOGY DELIVERED TO N.RC STAFF MAY 1986 l o
5 TEST PLANT APPLICATIONS DELIVERED TO NRC STAFF JUNE 1986 o INTERNAL IDCOR REVIEW OF METHODOLOGY APRIL-AUGUST 1986 l
a
, . , _ .m.- _ _ .m_. .- -- .
O O O
)~ ,
INTENSE IPEM EFFORTS ARE NEAR COMPLETION (2) l l NRC COMMENTS ON IPEM RECEIVED SEPTEMBER 1986 CALVERT CLIFFS IPEM DELIVERED TO NRC NOVEMBER 1986 l
- GRAND GULF TEST A3 PLICATION REVIEWED WITE NRC NOVEMBER 1986 i
REVISED METEODOLOGY TO BE SUBMl"TED
- TO hRC DECEMBER 1986 l
I I
~
O .
^986 APRIL 3 NRC/IDCOR MEErlNG ON REVIEW STANDARD MAY 2 IDCOR IPEM DRAFT REPORTS SUBMITTED TO NRC MAY 14/15 IDCOR IPEM WORKSHOP PRESENTED TO NRC' MAY 19 NRC C0 ORDINATION MEETING FOR REVIEW 0F IPEM JUNE 19 NRC MEETING TO CONSOUDATE REVIEW COMMENTS O JUNE 25 NRC REVIEWER'S PREUMINARY EVALUATIONS JUNE 26 5 IDCOR IPEM APPUCATIONS DRAFT REPORTS SUBMITTED TO NRC SEPTEMBER 9 NRC PREUMINARY EVALUTION SUBMITTED 10 IDCOR SEPTEMBER 24 IPEM MTG. WITH ACRS CLASS 9 SUBCOMMITTEE NOVEMBER 17/18 NRC AUDIT AT MP&L FOR GRAND GULF IPE DECEMBER 3 CALVERT CUFFS' DRAFT IPE REPORT SUBMITTED TO NRC .
DECEMBER 12 IDCOR RESPONSES TO NRC IPEM COMMENTS DECEMBER 16 IDCOR IPEM REV 01 SUBMITTED TO NRC DECEMBER 18 NRC/IDCOR ON VULNERABlUTIES DECEMBER 19 IPEM MTG. WITH ACRS Cl. ASS 9 SUBCOMMITTEE -
O
O
SUMMARY
1987 4
JANUARY RECEIPT OF GRAND GULF APPUCATIONS REPORT
! JANUARY 29 NRC/IDCOR MTG. ON SOURCE TERM METHODOLOGY O FEBRUARY 5 NRC/IDCOR-MTG. ON BWR IPE METHODOLOGY FEBRUARY 10/11 NRC AUDIT AT TVA ON SEQUOYAH IPE FEBRUARY 12/13 NRC AUDIT AT DUKE POWER ON OCONEE IPE FEBRUARY 19/20 NRC AUDIT AT ULC0 ON SHOREHAM IPE MARCH 1 RECEIPT OF SEQUOYAH APPUCATIONS REPORT MARCH 1 IDCOR IPEM REV 02 SUBMITTED TO NRC MAY NRC REGIONAL WORKSHOPS ON GENERIC LETTER /IPEM .
MAY -
IDCOR REGIONAL WORKSHOPS ON IPEM O
O ^
l O O O TECHNICAL ADVISORY GROUP CHAIRED BY DR. LEVERETT PLAYED IMPORTANT REVIEW i
ROLE IN DEVELOPING IPEM
- FORMED TEAM MARCH 1986 a METHODOLOGY PRESENTED TO TEAM i i
APRIL 1986 REVIEW CONDUCTED OF TWO TEST PLANT APPLICATIONS MAY 1986 l PERFORMED EVALUATION OF PLANNED l CHANGES AUGUST 1986 j
- TEAM RECOMMENDATIONS RECEIVED l (FINAL) OCTOBER 1986 l
l l - ;
l " imm _
O O O NRC REQUIRES ONLY LIMITED'IPE j
DOCUMENTATION BE SUBMITTED CERTIFICATION THAT IPE HAS BEEN COMPLETED PER GENERIC LETTER i
j
SUMMARY
OF RESULTS (CORE DAMAGE FREQUENCY i
AhD CONTAINMENT PERFORMANCE) AND INSIGHT GAINED FROM IPE i
l LIST OF IDENTIFIED VULNERABILITIES (lF ANY)
=
l DESCRIPTION OF SEVERE ACCIDENT MANAGEMENT l PROCEDURES '
EQUIPMENT NEEDED FOR ACCIDENT MANAGEMENT .
i '
l ,. o o I o.
i' NRC REQUIRES UTILITY TO RETAIN ~ ALL IPE ;
DOCUMENTATION FOR LIFE OF PLANT ,
3 SYSTEM NOTEBOOKS l CALCULATIONS AND ANALYSES IPE WORKSHEETS
}
- INSPECTION REPORTS
- AUDIT REPORTS
)
i
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l
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Il $$ 9590 2%
k 6 O O O .
IPE METHODOLOGY HAS UNDERGONE I
EXTENSIVE TEST APPLICATIONS l
! o BWRs -
i -
PEACH BOTTOM SUSQUEFANNA SiOREiAM ,.
j -
GRAND GULF '
I o PWRs 1
Zl0N 4
OCONEE J -
SEQUOYAH -
i CALVERT CLIFFS ~
i .
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. _ _ _ _. ~_ _ -
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l i
OVERVIEW OF THE IDCOR INDIVIDUAL PLANT EVALUATION METHODOLOGY JIM CARTER IT CORP.
! l PRESENTED TO: ,
ADVISORY COMMITTEE FOR REACTOR SAFETY JUNE 5,1987 l WASH 1NGTON,D.C.
i l ,
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PRESENTATION OUTLINE .
1 e REVIEW THE GOALS OF THE IPE METHODOLOGY.
I e REVIEW THE " SYSTEM" IMPORTANCE IN THE PLANT -
l l ANALYSIS.
l O e REVIEW THE " SYSTEM" IMPORTANCE IN THE -
l .
l SOURCE TERM EVALUATION.
e REVIEW THE INTERACTIONS BETWEEN THE PLANT -
ANALYSIS AND SOURCE TERM EVALUATION.
e e
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GOALS OF THE IPE i
e TO PROVIDE THE SYSTEMATIC, PLANT SPECIFIC EVALUATIONS REQUIRED BY THE SEVERE ACCIDENT ,
i POLICY STATEMENT. -
- CORE DAMAGE PREVENTION CAPABILITY.
i .
- UNUSUALLY POOR CONTAINMENT PERFORMANCE.
l .
i -
e TO PROVIDE A SYSTEMATIC, SYSTEM OPERATION AN PROCEDURE ORIENTED EVALUATION OF .A l
O GIVEN PLANT. .
l
\
e TO PROVIDE AN APPROACH WHEREIN THE INSIGHTS GAINED FROM THE SYSTEMATIC EVALUATION ARE CLEAR AND CAN BE USED IN DECISIONMAKING.
e TO PROVIDE A SYSTEMATIC METHODOLOGY WHICH -
CAN BE REVIEWED BY THE NRC IN A TIMELY MANNER.
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1 nm._w,.,,,_.~m_._ ,w..wy . , , ., _, __ ,_,. ,
L
\O l D INDIVIDUAL PLANT EVALUATION METHODOLOGY OPEgATOR ACTIONS .
S YSTEMS AVAILABtg SEQUENCE SYSTEM DEFINITION
^
SOWCE l
! (PLANT).
TERM ASSESSMENT
' ANALYSIS ,
CHECK ON TH j YSTEMS AVAILAB
\ NIAINMENT ISOLA l '
i \
l \ g
\ g EVALUATION OF :
h OUTLIER NMN '
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SUCCESS \
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CONDITIONS CRITERIA \
s I MAAP MODULAR ACCIDENT -
! ANALYSIS PROGRAM I
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REVIEW THE GOALS OF THE IPE METHODOLOGY i
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NRC SEVERE ACCIDENT POLICY Recognizing that plant-specific PRAs have -
yleided valuable insights to uhique plant vulnerabilities to severe accidents leading to low-cost modifications, licensees of each .
operating reactor will be expected to perform a limited-scope, accident safety . analysis designed to discover instances of particular -
vulnerability to core melt or to unusually poor i
0 containment performance.
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EXAMPLES OF IMPROVED SUCCESS CRITERIA BWRs e CRD FLOW FOR EVENTS WITH SUCCESSFUL SCRAM
~
AND LOSS OF ECCS SYSTEMS ON DEMAND.
e ATWS.RELATED EVENTS WITH OPERATOR ACTIONS FOLLOWING PLANT SPECIFIC EOPs.
' \
P_yVRs-e 'LOCA EVENTS WITH STEAM GENERATOR DEPRES-SURIZATION (REFLUX COOLING) WITH SUBSE.QUENT RECOVERY OF ECCS SYSTEMS.
l i e FEED AND BLEED CONDITIONS.
1 i
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l REVIEW THE " SYSTEM" IMPORTANCE IN THE PLANT ANALYSIS -
l O .
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BWR AND PWR IPE METHODOLOGIES e SYSTEM ORIENTED. .
- INCLUDES FRONT LINE SYSTEMS.
- INCLUDES SUPPORT SYSTEMS. .
e POWER (AC/DC).
e WATER.
e CONTROL.
e OPERATIONALLY ORIENTED.
i
- PLANT HISTORY / DATA. -
- '"AT RS.
O e SYSTEM PERFORMANCE. .
e COMPONENT PERFORMANCE.
- PLANT MAINTENANCE PROCEDURES AND HISTORY.
- PLANT SURVEILLANCE PROCEDURE. -
e PROCEDURALLY ORIENTED. ,
- PLANT HISTORY. ..
- OPERATOR TRAINING IN EOPs/FRGs.
- ADDITIONAL PLANT SPECIFIC PROCEDURES.
O ,
l
O -
SCOPE OF THE METHODOLOGY o ADDRESSES INTERNAL EVENTS.s .
~
o NOT A PRA, BUT THE SYSTEMS ANALYSIS CAN BE .-
EXPANDED TO A LEVEL 1 PRA.
o SYSTEM MODELS ARE ASSEMBLED AT A HIGH + -
i LEVEL.
o INCLUDES CRITICAL SAFETY FUNCTIONS AND FRONT LINE SYSTEMS WHICH FULFILL THESE FUNCTIONS.
o FRONT LINE SYSTEMS INCLUDE BOTH SAFETY AND NON-SAFETY RELATED SYSTEMS. ,
. o SUPPORT SYSTEMS AND THEIR DEPENDENCIES ARE- -
- EXPLICITLY ADDRESSED. .
- AC POWER.
- DC POWER.
/
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. SYSTEM NOTEBOOK FORMAT e FUNCTION
~
e SYSTEM DESCRIPTION .
- SUPPORT SYSTEMS
- INSTRUMENTATION AND CONTROL .
- - TEST AND MAINTENANCE l
4
- TECHNICAL SPECIFICATION LIMITATIONS e SYSTEM OPERATION e PERFORMANCE DURING ACCIDENT CONDITIONS e LOCATION WITHIN THE PLANT lg l e OPERATING EXPERIENCE -
l l e LOGIC MODELS e INITIATING EVENT REVIEW e QUANTIFICATION e
SUMMARY
OF KEY FINDINGS e
SUMMARY
OF KEY REVIEW COMMENTS e REFERENCES l
~
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APPLICATION OF THE METHODOLOGY .
o COLLECT PLANT DATA.
o DOCUMENTATION OF SYSTEM DESCRIPTIONS.
i o CONFIRM DESIGN DESCRIPTION BY PLANT WALK-DOWNS AND DISCUSSIONS WITH OPERATORS.
o IDENTIFY INITIATING EVENTS AND FREQUENCIES.
o IDENTIFY SYSTEM DEPENDENCIES.
O o MODEL SUPPORT SYSTEMS. -
o MODEL FRONT LINE SYSTEMS.
- FUNCTIONAL FAULT TREE SUPERCOMPONENTS .
(BWR).
- SYSTEM TEMPLATES (PWR).
o QUANTIFY ACCIDENT SEQUENCE FREQUENCIES .
THROUGH EVENT TREE MODELS.
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1 DEPENDENCY MATRIX DW CONTAINMENT RWEU/ H2 RE.
CHILLER SPRAYS RNR VENTING PCS/5FP COM9fMERS I !! I i 11 1 !! I 11 Offsite .
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TABLE 2.2-9 EXAMPLE IMPACT VECTOR ANALYSIS 0' . .
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Combinatiens State 1 A+8 A*8 A+8 A+8 A+5 A.B+C A+8 A+8 1 2 A+8 A+8 A A A A+C A A 2 ~
3 A+8 A+8 8 8 8 B+C B B 2 4 A+8 A+8 - - -
C 3 5 A4 A A+8 A A A.B+C A A 2
- 6 A4 A A A A A+C A A 2 7 A+8 A B B+C 3 8 A4 A - - -
C - -
3 9 A+8 8 A+8 B B A,9+C B B 2 10 A+8 B A A+C 3 11 A4 5 B B B B+C B B 2 0 12 13 14 A+8 A+8 A4 8
A+8 A
C C
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B C 3 16 A4 - - - -
C - - 4 Offsite AC Available/Offsite AC Unavailable 17 -
A+8 A+8 A+8 A+8 A+8 A B+C A4 A4 5 18 A+8 A+8 A A A A+C A A 6 19 A4 A4 B B B B4 8 8 6 20 A+8 A4 - - -
C - -
7 21 A+8 A A A A A+C A A 6 22 A+9 A C 7 23 A4 8 B B B 8+C B B 6 7
24 A+8 8 C 25 A4 - - - -
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8 maai m. -
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LIST OF SUPPORT SYSTEMS A. SERVICE WATER .
B. ENGINEERED SAFETY FEATURES ACTUATION C. COMPONENT COOLING D. ELECTRIC POWER - OFFSITE AC .
E. ELECTRIC POWER - ONSITE AC GENERATORS O .
F. ELECTRIC POWER - ONSITE DC G. INSTRUMENT AIR -
H. INTEGRATED CONTROL SYSTEM .
- l. HVAC O J e
SYSTEM OEPENDENCE MATRIX EE 2 % =
E 2
E 2 b
. . 2.# a ; ; % e !
- E e&* 2 %
3w 2.
F m R @ -
Example Matrix 3 j g g g "j .g g -
(Read Acress) he 8 5 2 Ft I I t T t E 8 I t u mF _t 3m 2 m 3 m Ib m m - E C
= .
Engineered Safety Features X X X X Integrated Centrol System X X X X Electric Power - Offsite AC O Electric Power - Onsite AC Electric Power - Onsite DC X X X X X X. X X Component Coeling Water X X X Service Water System X X X Instrument Air System X X HVAC System X X X Auxiliary / Emergency Feedwater X X X X X High Pressure Safety Injection X X X X X X Low Pressure Safety Injection X X X X X- X High Pressure Recirculation X X X X X X' Low Pressure Recirculation X X X X X X Chemical Volume & Centrol System X X X X X Main Feednater System X X X X X Main Steam System X X - Condensate System X X X X Accumulators / Core Fleed Tanks Centainment Fan / Coolers X X X X X X Centainment Spray System X X X X X X Recirculation Spray System X X X X X Ouench Spray System X X X X X X Ice Condenser System X X X Turbine Bypass System X X Reacter Protection System X X X X - PZR Power Operated Relief Valves A X O
O
~
REVIEW THE " SYSTEM" IMPORTANCE IN THE SOURCE ' TERM EVALUATION . O . 9 6 O 0 4 O , e
~
of . IPE SOURCE TERM METHODOLOGY j PWR 1 ICE CONDENSERS - l ESSENTIALLY THE SAME AS SEQUOYAH. .( i LARGE DRY - i INDEPENDENCE OF PRIMARY SYSTEM AND CONTAINMENT l AND PREVIOUS MAAP ANALYSES ALLOW A SIMPLIFIED M ELIN APPR ACH. KEY ELEMENTS ARE: O e TIME FOR DESRIS DRYOUT IN CONTAINMENT. e TIME OF CONTAINMENT FAILURE. e INERT AEROSOL GENERATION RATE. ' e AEROSOL SETTLIN.G RATES. , e TELLURIUM AND OTHER NONVOLATILE RELEASES. USES STREAMLINED CONTAINMENT EVENT TREES TO REPRESENT SEQUENCE DEPENDENCE. - o - t +ww- -=w-yw- y ww e, ye--ggma yw_- m yg-_ _ _ -
O O O . Is the debris covered and is containment heat Release Quantification removal a vailable ? Is the containment insignificant isolated 1 - IPE Methodology, is the containment Appendices A and G, O! O not bypassed? Releases much less than PWR-2-e g noble gasses plus ~ 5 % volatiles
~
Perform Detailed . Analysis if Required by Probability Appendix E IPE Methodology it Required by Probabillty 1 1 . Containment event tree. S 9
, b
O 1 I l 1 I CONTENTS AND PERFORMANCE OF THE BWR . METHODOLOGY l O . S l l l
~
, O . i
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- IPE SOURCE TERM METHODOLOGY BWR MARK I AND 11 CONTAINMENTS DEPENDENCE BETWEEN PRIMARY SYSTEM AND CONTAIN- .
4 MENT REQUIRES THE USE OF STREAMLINED CONTAIN-i MENT EVENT TREES FOR EVALUATING RELEASES. - KEY ELEMENTS: e CONTAINMENT FAILURE / VESSEL FAILURE. . e WETWELL VENTING. . e DRYWELL SPRAYS. e DEBRIS TRANSPORT TO THE SUPPRESSION POOL. MARK lli CONTAINMENT RELEASES FOR ALL ACCIDENT SEQUENCES ARE ESSENTIALLY NOBLE GASES. . l o - i
O STREAMLINED CONTAINMENT EVENT TREES e FOCUS ON THE MAJOR FISSION PRODUCT RETEN-TlON MECHANISMS IN THE CONTAINMENT. . 4 !O i
* ^" * ^ S7""C7""" ""7" VARIOUS SOURCE TERMS ON A SEQUENCE SPECIFIC
' S "7'" 7""
BASIS.- . e ARE SUFFICIENT FOR IDENTIFYING OUTLIER ' CONDITIONS. . O a 4
+,--m-me-wg ,,%,-w-* w -- m%ew,- _ w w ww_ .-w-w-we
l O LIKEllHOOD OF OCCURRENCE - e METHODOLOGIES USE HIGH, MEDIUM AND LOW. l e ACCEPTABLE PERFORMANCE - EVERY " POTENTIAL OUTLIER" PATH HAS AT LEAST ONE " LOW" OR TWO -
" MEDIUMS" AT THE BRANCH POINTS.
e OPERATOR ACTIONS MAY BE CREDITED, BUT ' O REoUiRE
- PROCEDURES OR DEMONSTRATED CAPABILITY.
l
~
- OPERATOR INTERVIEWS. ' ' '
- ASSESSMENTS OF KEY TIME INTERVALS.
e STEAM IN REACTOR BUILDING. e FISSION PRODUCTS IN CONTAINMENT. o - o v w e w w- e-ev e---g ww y* g--
o( ~ 3 CONTAINMENT BYPASS , e FREQUENCY OF OCCURRENCE < 10-6
- ACCEPTABLE. ,
e FREQUENCY OF OCCURRENCE > 10-6 - USE O REACTOR BUILDING / AUXILIARY BUILDING ' CHECKLIST. ! e CHECKLIST HIGHLIGHTS MAJOR RETENTION . ,, CAPABILITIES. - o . 4
O l D .l r
.l -
9 CONTAINMENT ISOLATION i e ANALYSES PERFORMED IN THE SYSTEMS ANALYSIS. i O e INVESTIGATE CONTAINMENT PENETRATIONS DOWN TO 2" DIAMETER. . e FOCUS ON HIGH LIKEllHOOD OF ISOLATION. . 1 . i 4 l
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. . . ~ . . _ . . -.
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, CONTAleseeENT COeITAtesteENT DESA8S FAEURE OR seOT teOT REACTOR COOL ABL E seePAestesENT sug Deseg SYPASSED teeFA88tED tong igne8 T E NitOM END STATE DAY WEtt EFFECitM j
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O O .~- O . , - ,1 l l t ! CONTAINMENT CONTAINMENT CONTAINMENT NOT OR DRYWELL VENTED OR END STATE BYPASSED NOT IMPAIRED FAILUR E , , ABOVE SP ^ 1 l . ! l lis- t 111 - 2 1 i i t j 118 - 3 APPENDIX A Mark III streamlined containment event tree for all accident classes.
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O O O N.' i MARK I END STATE DESCRIPTIONS (Accident Classes I and III) - i l Representative Source Tem End i State # Description Class I and III Class 11 and IV I-l ~ Containment not bypassed Noble Gases Noble Gases Containment not impaired Ex-vessel debris coolable long term i ! I-2 Containment not bypassed Noble Gases Noble Gases l Containment not impaired j Ex-vessel debris not coolable long tem - Wetwell vented, failed or impaired 4 I-3 Containment not bypassed tioble Gases Noble Gases Containment not impaired + 25 Volatiles + 101 Volatiles Ex-vessel debris not coolable long term + 0.15 + 0.11 l Drywell vented, failed or impaired Non-Volatiles Non-Volatiles
- Reactor building maximum effectiveness I-4 Containment not bypassed Potential Outlier Potential Outlier Containment not impaired 1 Ex-vessel debris not coolable long term
! . Drywell vented, failed or impaired l Reactor building minimum effectiveness
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